Search - 教職 奨学金免除
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Ruling summary
2012 Ruling 2011-0392041R3 - Incorporation of a Professional Partnership -- summary under Specified partnership income
New structure: Common Shareholders of Newco (following the entering into of a shareholders' agreement many of whose terms are similar to the former Partnership Agreement) will have the option of providing their services personally or by using a "New Contracting Corporation" which is owned by, and is the employer of, him or her – except that preference shares may be held by family members – so that each New Contracting Corporation will provide services for agreed fees, will be responsible for specified expenses such as professional membership fees, insurance premiums, education expenses, travel expenses and entertainment expenses (with Newco to provide each New Contracting Corporation with certain supplies, facilities and equipment but with their fair market value to be borne by the New Contracting Corporation), and with the New Contracting Corporation free to compete with Newco. ...
Ruling summary
2023 Ruling 2022-0923451R3 F - 55(3)(a) internal reorganization -- summary under Paragraph 55(2.1)(c)
The DSI of the transferor corporation (“Transferor”) that has accrued on the shares of its capital stock held by shareholders other than the transferee corporation (“Transferee”), determined immediately after the reorganization, will be calculated in accordance with the following formula: DSI on shares of capital stock of Transferor held by all shareholders immediately after the reorganization = DSI immediately before the reorganization X total net cost amount of property retained by Transferor / total net cost amount of all property of Transferor immediately before the reorganization. ...
Ruling summary
2013 Ruling 2011-0395091R3 - MFC to MFT Conversion -- summary under Paragraph (f)
Ruling that the transfers from the Direct Subtrusts to Trust A in 2 will not be considered a "disposition" by virtue of s. 248(1) – disposition, (f)(v), and Trust A will be deemed, to be the same trust as, and a continuation of, each of the Direct Subtrusts by virtue of s. 248(25.1); therefore the ACB of Taxpayer's interest in Trust A will be equal to the aggregate ACB of Taxpayer's interests in the Direct Subtrusts before the transfer. See detailed summary under s. 132.2 – qualifying exchange. ...
Ruling summary
2013 Ruling 2011-0395091R3 - MFC to MFT Conversion -- summary under Paragraph 20(1)(c)
See detailed summary under s. 132.2 – qualifying exchange. ...
Ruling summary
2013 Ruling 2013-0487911R3 - Mortgage Investment Corporation -- summary under Subsection 130.1(6)
. … Opco may advance funds to the LP from time to time for working capital and development… on arm's length commercial terms…. ...
Ruling summary
2009 Ruling 2009-0338731R3 - Public spin-off butterfly -- summary under Subsection 7(1.4)
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2010 Ruling 2010-0353121R3 - Deferred Share Unit Plan -- summary under Paragraph 6801(d)
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2014 Ruling 2013-0514191R3 - Debt restructuring, forgiveness and winding-up -- summary under Principal Amount
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2014 Ruling 2013-0514191R3 - Debt restructuring, forgiveness and winding-up -- summary under Subsection 39(2)
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2014 Ruling 2013-0514191R3 - Debt restructuring, forgiveness and winding-up -- summary under Section 51.1
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