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Technical Interpretation - Internal

21 November 2012 Internal T.I. 2012-0455501I7 - NPO Project

Position: Likely no Reasons: Fact specific November 21, 2012 Small & Medium Enterprises Directorate HEADQUARTERS 112 Kent Street, 19th Floor Income Tax Rulings Ottawa, ON K1A 0L5 Directorate Ann Townsend 905-721-5096 2012-045550 Attention: Rubin Dressler Non Profit Organization (“NPO”) Project- XXXXXXXXXX (the “Corporation”) This is in response to your correspondence of July 10, 2012, asking for our comments with respect to the tax-exempt status of the Corporation pursuant to paragraph 149(1)(l) of the Income Tax Act (the “Act”) for the XXXXXXXXXX and XXXXXXXXXX taxation years. ...
Technical Interpretation - Internal

16 June 2015 Internal T.I. 2015-0569011I7 - Clergy Residence Deduction

" The Residential Tenancies Act, 2006 (Ontario) states that "rent" includes, " the amount of any consideration paid or given or required to be paid or given by or on behalf of a tenant to a landlord or the landlord's agent for the right to occupy a rental unit and for any services and facilities and any privilege, accommodation or thing that the landlord provides for the tenant in respect of the occupancy of the rental unit, whether or not a separate charge is made for services and facilities or for the privilege, accommodation or thing... ...
Technical Interpretation - Internal

21 March 2014 Internal T.I. 2013-0504491I7 - Change to loss application in a nil assessed year

We also acknowledge several discussions concerning the file (Godson, Young / Bafia, Holly Carswell). ...
Technical Interpretation - Internal

26 August 2013 Internal T.I. 2013-0494211I7 - participating debt interest

August 26, 2013 Blair Hammond Angelina Argento Senior Advisor – Tax Treaties IT Rulings Directorate International, Provincial and (514) 283-7895 Strategic Policy Division Legislative Policy Directorate 2013-049421 Subparagraph 6(b) of Article XI of the Canada-U.S. ...
Technical Interpretation - Internal

22 January 2015 Internal T.I. 2014-0560571I7 - Paid-up capital reduction of a foreign affiliate

At the time of the investment, the exchange rate was $1US = $1 Canadian. ...
Technical Interpretation - Internal

24 December 2015 Internal T.I. 2014-0560831I7 - International shipping

The Taxpayer’s activities carried on in Canada consist primarily of XXXXXXXXXX, in order to satisfy the shipping requirements of certain related companies XXXXXXXXXX (the “Related Party Customers”) XXXXXXXXXX. 3. ...
Technical Interpretation - Internal

9 March 2016 Internal T.I. 2015-0612501I7 - ITA 261(21) anti-avoidance

Either the non-resident corporation does not have a tax reporting currency, or it has the Canadian dollar tax reporting currency the same as the Canadian-resident corporation. ...
Technical Interpretation - Internal

28 May 2012 Internal T.I. 2011-0421441I7 - Travel btwn temp residence and special work site

May 28, 2012 Ita Mackey Tom Posadovsky, CMA Trust Exam & Employer Compliance Audit IT Rulings Directorate Newfoundland and Labrador Tax Services Office Reorganizations Division Sir Humphrey Gilbert Building 165 Duckworth Street, PO Box 12075 (613) 952-8283 St. ...
Technical Interpretation - Internal

22 March 2012 Internal T.I. 2011-0412051I7 - Application of Subsection 149(5)

Specifically: It describes the purposes of the Corporation as "to encourage the instruction, practice, enjoyment and advancement of its members in all aspects of XXXXXXXXXX in accordance with the XXXXXXXXXX ". ...
Technical Interpretation - Internal

10 November 2011 Internal T.I. 2011-0410851I7 - Paragraph 149(1)(l)

The members live together in a building owned by a charity (the "XXXXXXXXXX "). ...

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