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Ruling summary

2014 Ruling 2013-0513211R3 - Butterfly Transaction -- summary under Subsection 186(1)

See summary under s. 55(1) distribution. ...
Ruling summary

2014 Ruling 2013-0516071R3 - Reorganization -- summary under Subsection 34.2(14)

2014 Ruling 2013-0516071R3- Reorganization-- summary under Subsection 34.2(14) Summary Under Tax Topics- Income Tax Act- Section 34.2- Subsection 34.2(14) transfer by Profitco of profitable LP to Lossco which is affiliated by virtue of common NR indirect parent The units of an LP (LP1) which already has earned profits for the year and which holds most of the units of LP2 will be transferred to a Lossco (which is affiliated and related by virtue of a common indirect parent) before the fiscal year end of LP1 so that most of those LP1 profits will be allocated to Lossco. ...
Ruling summary

2014 Ruling 2013-0516071R3 - Reorganization -- summary under Paragraph 96(1)(f)

2014 Ruling 2013-0516071R3- Reorganization-- summary under Paragraph 96(1)(f) Summary Under Tax Topics- Income Tax Act- Section 96- Subsection 96(1)- Paragraph 96(1)(f) transfer of profitable LP to Lossco followed by allocation of previously-earned profits of LP to Lossco CRA ruled on a transaction in which (to simplify somewhat) the units of an LP (LP1) which already has earned profits for the year will be transferred to the Lossco before the fiscal year end of LP1 so that most of those LP1 profits will be allocated to Lossco. ...
Ruling summary

2015 Ruling 2014-0536661R3 - Disposition of property by a foreign partnership -- summary under Excluded Property

See summary under s. 95(1) foreign accrual property income. ...
Ruling summary

2016 Ruling 2015-0606771R3 - Disclaimer of trust interest -- summary under Subsection 107(1)

B on an intestacy would not result in any of the grandchildren receiving proceeds of disposition, and that such distribution would occur under s. 107(2). ...
Ruling summary

2016 Ruling 2015-0606771R3 - Disclaimer of trust interest -- summary under Disposition

B on an intestacy would not result in any of the grandchildren receiving proceeds of disposition. ...
Ruling summary

2017 Ruling 2016-0674681R3 - Sequential Split-Up Butterfly -- summary under Paragraph 55(3.1)(a)

2017 Ruling 2016-0674681R3- Sequential Split-Up Butterfly-- summary under Paragraph 55(3.1)(a) Summary Under Tax Topics- Income Tax Act- Section 55- Subsection 55(3.1)- Paragraph 55(3.1)(a) sale of securities for cash proceeds that are reinvested, and tendering shares for shares of offeror Preliminarily to a butterfly distribution that was favourably ruled upon, DC1 sold portfolio investment units for cash, and may reinvest the proceeds in marketable securities or other investments transactions that are represented to be independent of the butterfly transactions. ...

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