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Technical Interpretation - Internal

1 March 2004 Internal T.I. 2003-0053821I7 - Employee vs. Contractor - Shareholder

If you have questions on a specific matter with respect to the determination of an employment status, please contact the CPP / EI Eligibility Division of the Assessment and Collections Branch. ...
Technical Interpretation - Internal

12 March 2004 Internal T.I. 2004-0064901I7 - Passenger Vehicles

Brian Olsen HEADQUARTERS Northern BC & Yukon Tax Services Office Randy Hewlett, B.Comm. 613-957-8973 2004-006490 Definition of "Passenger Vehicle"- Income Tax Act ("the ITA") We are writing in response to your request for our opinion on the definition of "passenger vehicle" in subsection 248(1) of the ITA, as it pertains to certain motor vehicles that are used in a business activity which is not considered a "commercial activity" for purposes of the Excise Tax Act (the "ETA"). ...
Technical Interpretation - Internal

30 March 2004 Internal T.I. 2004-0060591I7 - Taxation of relocation benefit of Indian employee

It should be taxed in the same proportion as the subsequent / resulting employment income. ...
Technical Interpretation - Internal

13 May 2004 Internal T.I. 2003-0047991I7 - Refundable ITC

" As you note, paragraph 87 of IT-151R5 states, in part "... corporations (and associated corporations) whose taxable capital employed in Canada in the previous taxation year... exceeds $15 million will not have a business limit (see paragraph 81) and, therefore, will not meet the conditions to be a qualifying corporation. ...
Technical Interpretation - Internal

18 June 2004 Internal T.I. 2004-0073061I7 - Sale of Farm Inventory

Lloyd Clark & Co. Ltd. (1970 CarswellNat 142), the Tax Appeal Board stated: "...that payment of a purchase price is basically not effected by the delivery of a promissory note unless the governing agreement for sale provides specifically for that particular mode of payment... ...
Technical Interpretation - Internal

26 August 2004 Internal T.I. 2002-0142171I7 - Superanuation or pension benefit

August 26, 2004 INTERNATIONAL TAX DIRECTORATE HEAD OFFICE Non-resident Operations Division Income Tax Rulings Returns Processing & Compliance Directorate R. ...
Technical Interpretation - Internal

17 April 2001 Internal T.I. 2001-0077357 - US PENSION CANADIAN BENEFICIARY

DOCUMENT TYPE: Tax Services Office Memo 2001-007735 Principal Issues: Are amounts received from a deceased sister’s U.S. pension plans taxable in the hands of the Canadian beneficiary Position: Yes. ...
Technical Interpretation - Internal

16 May 2001 Internal T.I. 2001-0081167 - EQUIVALENT-TO-SPOUSE CREDIT

How long does the dependent have to reside with parent / guardian in order to qualify for equivalent-to-spouse credit? ...
Technical Interpretation - Internal

19 June 2001 Internal T.I. 2000-0053887 F - STATUTE-BARRED YEARS - GST CREDIT

À moins d'indication contraire, tous les renvois législatifs ci-après sont des renvois aux dispositions de la Loi de l'impôt sur le revenu, " la Loi". ...
Technical Interpretation - Internal

20 August 2001 Internal T.I. 2001-0092797 - MULTI-EMPLOYER PENSION RELATED GROUP

For the purposes of the Act, subsection 251(2) provides that, persons related to each other are: individuals connected by blood relationship, adoption, marriage or common-law partnership; a corporation and a person that controls the corporation a person who is a member of a related group that controls the corporation, or any person related to a person described in either of the above two situations; and * any two corporations if they are controlled by the same person or group of persons, if each of the corporations is controlled by one person and the person who controls one of the corporations is related to the person who controls the other corporation, if one of the corporations is controlled by one person and that person is related to any member of a related group that controls the other corporation, if one of the corporations is controlled by one person and that person is related to each member of an unrelated group that controls the other corporation, (v) if any member of a related group that controls one of the corporations is related to each member of an unrelated group that controls the other corporation, or (vi) if each member of an unrelated group that controls one of the corporations is related to at least one member of an unrelated group that controls the other corporation. ...

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