Search - 枣庄市市中区 智博公考 地址 电话

26 June 1989 Ministerial Letter 58158 F- Withholding Tax on Payments made to Non-Residents Unedited CRA Tags 212(1)(d)(vi) 19(1) File No. 5-8158   K.B. Harding   (613) 957-2129 June 26, 1989 Dear Sirs: This is in reply to your letter of May 26, 1989 concerning the obligation to withhold tax on payments made to non-residents in respect of a copyright and in respect of the production or reproduction of computer programs prior to June 8, 1988. ...

DathDirectorBusiness and General DivisionRulings Directorate cc.      ...

15 November 1989 Ministerial Letter 58958 F- Qualified Small Business Corporation Share Unedited CRA Tags 110.6(1) qualified small business corporation share 19(1) File No. 5-8958   S. Leung   (613) 957-2116 November 15, 1989 Dear Sirs: Re:  Qualified Small Business Corporation Share ("QSBC Share") We are writing in response to your letter of October 11, 1989 wherein you requested our opinion on whether, in the situation described below, the time during which the person held the shares of a corporation would be included in meeting the 24 month test pursuant to paragraph (b) of the definition of "QSBC Share" in subsection 110.6(1) of the Income Tax Act (the "Act"). ...

23 January 1990 Ministerial Letter 59098 F- Employee Share Purchase Plan Unedited CRA Tags 7, 32.1 19(1) File No. 5-9098   W.C. Harding   (613) 957-3499 January 23, 1990 Dear Sirs: Re:  Employee Share Purchase Plans This is in reply to your letter of November 15, 1989 wherein you requested our consideration of a proposed model share purchase plan. ...

21 August 1990 Ministerial Letter EACC9288 F- Divisive Reorganization Unedited CRA Tags 55(3)(b), 85(1), 85.1(1)   August 21, 1990   EACC9288 DIVISIVE REORGANIZATION QUESTION For the purposes of paragraph 55(3)(b) of the Act, all of the properties owned by the particular corporation are of one type. ...

31 July 1989 Ministerial Letter 73898 F- Acquisition of Fishing License- Requirement to Reduce Cost by Amount of Government Assistance Unedited CRA Tags 12(1)(x), 14(5) eligible capital expenditure   July 31, 1989 VANCOUVER DISTRICT OFFICE Small Business and Audit Division General Division Section 144-24 Bill Guglich   (613) 957-2102 David K. ...

2 October 1990 Ministerial Letter 902538 F- Donation made by Vendor Unedited CRA Tags n/a 24(1) 902538   C. Tremblay   (613) 952-1361 19(1) October 2, 1990 Dear Sirs: 24(1) This is in reply to your letter of September 13, 1990, concerning the offers to purchase the above named property. ...

You seek our opinion with respect to different situations. (1)      Repayment of Government Assistance: A) In your example, on June 1, 1993, an Excise reassessment results in a $100 increase to the 1991 GST liability of a taxpayer.  ... You may wish to consult with Current Amendments in this regard. (2)      Receipt of Government Assistance You ask us to consider a situation where a taxpayer is informed on June 1, 1993, by a GST auditor that previously unclaimed input tax credits of $100 are available in respect of a June 1, 1991 expense. ... Note that under section 296 of the Goods and Services Tax the Minister may take into account any amount unclaimed as an input tax credit, deduction or refund and any overpayment of tax with respect to the reporting period being assessed. (3)      Effect of the GST on Sales Proceeds You ask that we consider the following comments and provide our opinion with respect to the issue. ...

DM'S OFFICE (2) # 97-03007M ASSOCIATE DEPUTY MINISTER (1) # 97-02908M ADM'S OFFICE (2) PENDING RETURN TO INCOME TAX RULINGS AND INTERPRETATIONS DIRECTORATE 15TH FLOOR, ALBION TOWER Signed on July 4, 1997 XXXXXXXXXX Dear XXXXXXXXXX: I am responding to your letter addressed to the Honourable Paul Martin, Minister of Finance, concerning the administration of the Income Tax Act. ...

Principal Issues: Explanation of development and purpose of administrative and/or interpretive positions Position: Self-explanatory Reasons: N/A ADM'S OFFICE (2) # 97-03761M RETURN TO 15TH FLOOR, ALBION TOWER Signed on July 4, 1997 XXXXXXXXXX Dear XXXXXXXXXX: I am writing in response to your letter of May 20, 1997, addressed to the Honourable Jane Stewart, former Minister of National Revenue concerning the administrative position adopted by the Department regarding the deductibility of interest expense incurred on funds borrowed to make corporate or partnership distributions of capital or earnings. ... Denis Lefebvre Assistant Deputy Minister Policy & Legislation Branch J.P. ...