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Technical Interpretation - Internal summary
3 April 2019 Internal T.I. 2018-0787561I7 - Partnership and the Meaning of "Related" -- summary under Subparagraph 251(2)(c)(i)
In the case of a limited partnership … it is usually the general partner that can exercise these rights. ...
Technical Interpretation - Internal summary
9 February 2022 Internal T.I. 2020-0873931I7 - Cover Letter - Mining Expenditure Review Table -- summary under Current expense vs. capital acquisition
The following are deductible under s. 9 if incurred before making a decision to bring the mine into production (otherwise generally Class 41 or 41.2 assets or other depreciable property, or Class 14.1 if the property is not acquired – or CDE under para. ...
Technical Interpretation - Internal summary
16 December 2019 Internal T.I. 2019-0816101I7 - Loans from LTD Partnerships to LTD Partner -- summary under Section 96
Rye / Klein line of cases): It is well established at common law that a man cannot contract with himself and that a partner cannot contract with a partnership of which he is a member. ...
Technical Interpretation - Internal summary
23 August 2023 Internal T.I. 2021-0882371I7 - Dividend payment and 94.1(1)(g) -- summary under C
The effect of C of the FAPI formula was that the OIFP rules generated FAPI to CFA, and Canco then picked up its share of such FAPI – and this combined operation of the FAPI and OIFP rules was not affected by dividends paid by FA to the CFA (inter-FA dividends are excluded form FAPI) nor was it affected by any dividends paid by CFA to Canco. ...
Technical Interpretation - Internal summary
21 December 2022 Internal T.I. 2019-0826411I7 - Classification of a Burkina Faso SARL -- summary under Section 96
., a provision in the governing Act providing that a SARL “is created by (one or more) persons that agree, through an agreement, to contribute, to an activity, cash, or in-kind or services assets for the purpose of sharing profits or enjoying revenues that may derive therefrom” – but, overall, its attributes were closer to those of a Canadian corporation than of a partnership. ...
Technical Interpretation - Internal summary
19 December 2000 Internal T.I. 2000-0009277 F - Fosse pour traitement du fumier -- summary under Paragraph 1(q)
. … [Furthermore] the pit is permanently fixed to the ground, which constitutes a permanent foundation. ...
Technical Interpretation - Internal summary
18 September 2000 Internal T.I. 2000-0043647 F - Perte transfert bâtiment personne affiliée -- summary under Subsection 13(21.1)
On the sale, it realized a capital gain of $50,000 and a terminal loss of $60,000 – except that, pursuant to s. 13(21.1), the capital gain became nil and the terminal loss became $10,000, so that pursuant to s. 13(21.1), the deemed proceeds of disposition of the building were $250,000. ...
Technical Interpretation - Internal summary
29 August 2000 Internal T.I. 2000-0023187 F - Société privée sous contrôle canadien -- summary under Subparagraph 251(2)(b)(i)
After noting that “[w]here … a limited partnership has only one general partner, the Agency's position is that the general partner generally has control of the limited partnership,” CRA indicated that C Ltd. thus controlled Opco, and that the “ultimate control” of Opco, as described in Parthenon, was held by A Ltd. ...
Technical Interpretation - Internal summary
13 January 2012 Internal T.I. 2011-0414111I7 F - Deemed Interest Incomes - Exception 17(8) -- summary under Subparagraph 17(8)(a)(ii)
In this regard, CRA quoted a judicial statement that "the courts have concluded that the concept of loan or advance is related to the existence of a payment of money between two parties and to the presence of that relationship of lender / borrower," and then stated: [T]he contractual relationship between CFA 1 and CFA 2 with respect to the Debt establishes a creditor/debtor relationship and not a lender/borrower relationship. ...
Technical Interpretation - Internal summary
Memorandum 17-6 "Definition of ‘Listed Financial Institution'" July 2014 -- summary under Paragraph 149(1)(a)
. … CRA considers that "principal" refers to the person's chief or main business activity. ...