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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. ...

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