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Technical Interpretation - Internal summary
9 June 2011 Internal T.I. 2011-0396721I7 F - Déduction - habitants de régions éloignées -- summary under Subsection 110.7(1)
. … [I]n the situation you described, an individual who resides in a prescribed northern or intermediate zone for a period of at least six months and who has a 35-day work cycle in the said zone followed by an 8-day leave in his other residence at XXXXXXXXXX would be entitled to the deduction provided for in section 110.7. ...
Technical Interpretation - Internal summary
7 January 2011 Internal T.I. 2010-0387011I7 F - DPA dans une année prescrite -- summary under Revising Claims
…[T]he CRA should not accept the adjustment request … as it would result in changes to the tax assessment for Year 1, which is a statute-barred year. ...
Technical Interpretation - Internal summary
6 April 2010 Internal T.I. 2009-0343091I7 F - Montant pour enfant -- summary under Paragraph 118(4)(b)
. … Since Mr. A and Ms. B lived in separate self-contained domestic establishments during the period of the year in which they lived apart, the concept of the same "self-contained domestic establishment" in 118(4)(b) does not restrict the right of Mr. ...
Technical Interpretation - Internal summary
30 September 2010 Internal T.I. 2010-0373901I7 F - Bigamie fiscale - transfert de biens au décès -- summary under Subparagraph 40(4)(b)(i)
30 September 2010 Internal T.I. 2010-0373901I7 F- Bigamie fiscale- transfert de biens au décès-- summary under Subparagraph 40(4)(b)(i) Summary Under Tax Topics- Income Tax Act- Section 40- Subsection 40(4)- Paragraph 40(4)(b)- Subparagraph 40(4)(b)(i) application of s. 40(4)(b)(i) by both surviving spouse re House A and surviving common-law partner re House B – but not for overlapping years The taxpayer lived with his spouse in Immovables A, but thereafter commenced to live separate and apart from her, but did not divorce from her, and instead lived in a conjugal relationship with another (a common-law partner) in Immovable B until his death. ...
Technical Interpretation - Internal summary
9 December 2010 Internal T.I. 2010-0371741I7 F - Automobiles mises à la disposition des employés -- summary under Automobile
In both of the situations described above, since the vehicles … are designed and constructed with more than three seating positions and are not similar to a van or pick-up truck, we are of the view- based on their use- that those vehicles are automobiles for the purposes of the Act. ...
Technical Interpretation - Internal summary
12 August 2010 Internal T.I. 2010-0356781I7 F - Allocation de retraite, indemnité 2091 C.c.Q. -- summary under Retiring Allowance
. … [I]n the majority of circumstances, the compensation paid by the employer under C.C.Q Article 2092. appears to be to compensate for a prejudice caused by the absence of notice. ...
Technical Interpretation - Internal summary
24 January 2011 Internal T.I. 2010-0390111I7 F - GRIP Computation and Taxable Income for M&P Credit -- summary under Subsection 89(7)
. … It is clear to us, having regard to the provisions of elements I and J of element B of the formula in the definition of GRIP, that the MPPD Amount for a taxation year is not taken into account for purposes of the calculations. ...
Technical Interpretation - Internal summary
15 March 2010 Internal T.I. 2009-0323081I7 F - Frais pour droit d'usage -- summary under Element B
CRA stated: [T]here is no taxable benefit where an employee uses an Employer's automobile to drive from his or her home to the … customer. ...
Technical Interpretation - Internal summary
25 October 2016 Internal T.I. 2016-0658241I7 - Application of 95(2)(a.1) to a capital gain -- summary under Subparagraph 95(2)(a.1)(iv)
.] … Variable B of the FAPI definition applies specifically to capital gains, whereas income from a business other than an active business, such as income from the sale of property which meets the conditions of paragraph 95(2)(a.1), would fall under variable A of that definition. ...
Technical Interpretation - Internal summary
18 October 2016 Internal T.I. 2016-0640321I7 - Subsections 152(1.5) and 244(20) -- summary under Subsection 244(20)
[A] similar conclusion was arrived at in… Menzies …. [S]ubsection 244(20) relieves the Minister from its obligation to send a notice of determination to each person who was a member of the partnership during the fiscal period covered by the notice of determination where the notice of determination is mailed to, served on or otherwise sent to the partnership at the latest known address of the partnership. ...