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Technical Interpretation - Internal summary
31 August 2000 Internal T.I. 2000-0038757 F - ALLOCATIONS POUR FRAIS DE DEMENAGEMENT -- summary under Paragraph 6(1)(b)
. – but further provided that in special justifiable circumstances, reimbursement of the following allowances could be authorized: a) a compensatory allowance for the self-moving of furniture, equal to 50% of the estimate of a moving firm, b) a compensatory allowance for the self-sale of the residence, established at 3% of the sale price, and c) in the event that the employee waived the employee’s right to the reimbursement of moving expenses, a compensatory allowance for additional moving expenses equaling 50% of the following: certain related expenses, real estate agent fees equivalent to 6% of the residence’s municipal evaluation, notary fees of $850 and the amount of a moving company estimate. ...
Technical Interpretation - External summary
23 September 1998 External T.I. 9800555 F - FIDUCIE SUCCESSIVE - FIDUCIE TESTAMENTAIRE -- summary under Subsection 248(9.1)
Consequently, in the example … a trust created for a minor child under the will would be considered a “testamentary trust” under the definition in subsection 108(1), assuming that paragraphs (a), (b) and (c) of that definition do not apply. ...
Technical Interpretation - Internal summary
10 July 2000 Internal T.I. 2000-0022027 F - OBLIGATION LÉGALE DE PAYER UNE DÉPENSE -- summary under Paragraph 18(1)(e)
If the facts show that it is only the time of payment that is not precisely established, but that there is no uncertainty as to the payment of the amount … it could then be a future obligation to pay and not a contingent obligation. ...
Technical Interpretation - External summary
2 June 2000 External T.I. 1999-0011325 - Specified Partnership Income -- summary under Paragraph 96(1)(f)
. … [N]o partner should be allocated an amount of income greater than the income realized by the partnership. ...
Technical Interpretation - External summary
25 March 2025 External T.I. 2024-1039131E5 - CCUS - "actual eligible use percentage" -- summary under Actual Eligible Use Percentage
However, as the unanticipated fugitive emissions occur within Bco’s pipeline transportation network, Aco may be able to avail itself of the relief provided in subsections 211.92(6) and (7) … because such emissions would likely be due to extraordinary circumstances outside of the control of Aco. ...
Technical Interpretation - External summary
25 March 2025 External T.I. 2024-1039131E5 - CCUS - "actual eligible use percentage" -- summary under Subsection 211.92(6)
However, as the unanticipated fugitive emissions occurred within Bco’s pipeline transportation network, “Aco may be able to avail itself of the relief provided in subsections 211.92(6) and (7) … because such emissions would likely be due to extraordinary circumstances outside of the control of Aco.” ...
Miscellaneous summary
12 June 2000 Income Tax Severed Letter 2000-0024916 F - ACCOMPLIT PRINCIPALEMENT -- summary under Subparagraph 8(13)(a)(i)
. … When the employer completes Part 9 of the form, it should be noted that the employer does not have to ascertain in person the time that the employee will devote to work at home: the employer must simply state whether or not the employer has obliged the employee to rent an office or to use part of the employer’s home for work purposes. ...
Technical Interpretation - External summary
24 June 2025 External T.I. 2025-1063501E5 - Clean Hydrogen ITC - Operating Year -- summary under Operating Year
24 June 2025 External T.I. 2025-1063501E5- Clean Hydrogen ITC- Operating Year-- summary under Operating Year Summary Under Tax Topics- Income Tax Act- Section 127.48- Subsection 127.48(1)- Operating Year periods where hydrogen continues to be produced are not disregarded The concept of an “operating year” is defined to “disregard … any period during which the project is not operating”, so that, for example, if it did not operate for one month, the operating year might be 13 months. ...
Technical Interpretation - External summary
4 April 2024 External T.I. 2023-0996201E5 - Employment income to sole shareholder -- summary under Section 87
The proportion of 70% of the salary earned by the Physician could be considered to be situated on the Reserve and would therefore be exempt from tax …. ...
Technical Interpretation - Internal summary
19 April 2000 Internal T.I. 2000-0005387 F - DEFINITION DE VEHICULE A MOTEUR -- summary under Motor Vehicle
However, before concluding that “a snowmobile is … not a motor vehicle since it is not designed or equipped for use on public roads,” it stated: The first expression used, “designed or adapted” should, in our view, be used not in the sense of “capacity” but rather in the sense of “having or being organized for a specific use.” ...