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Technical Interpretation - Internal
31 January 2013 Internal T.I. 2012-0470361I7 - PIA - Non-manufactured goods (ITR 402(4.1))
For example, subparagraphs 402(4)(c)(i) and (ii) state, "if the merchandise was produced or manufactured or produced and manufactured, partly in the particular province and partly in another place by the taxpayer,
". ...
Technical Interpretation - Internal
8 August 2013 Internal T.I. 2013-0483291I7 - ETC and TTC - XXXXXXXXXX
Each of these highlighted terms is defined in subsection 118.6(1) of the Act and is explained in more detail in paragraphs 1.9 1.25 of Income Tax Folio S1-F2-C1. ...
Technical Interpretation - Internal
22 January 2016 Internal T.I. 2015-0586673I7 - Self-governing First Nations in the Yukon and BC
A "Yukon Indian Person", as defined in Chapter 1 of the UFA, is a person enrolled under one of the Yukon First Nation Final Agreements in accordance with criteria established in Chapter 3 — Eligibility and Enrollment. ...
Technical Interpretation - Internal
15 March 2016 Internal T.I. 2014-0549701I7 - Obligation of Crown corporations to file a T106
Requirement to file a T106 The requirement to file form T106 – Information return of non-arm’s length transactions with non-residents for a particular taxation year is governed by section 233.1, which falls under Part XV of the Act. ...
Technical Interpretation - Internal
3 February 2011 Internal T.I. 2008-0301631I7 - tuition tax credit - University outside Canada
" and further stating that it includes " the members of this collectively". ...
Technical Interpretation - Internal
24 October 2011 Internal T.I. 2011-0404731I7 - XXXXXXXXXX -Paragraph 149(1)(l)
The funds for these expenses must come from "amounts contributed to the fund on behalf of the XXXXXXXXXX " (it is not clear to us what amount is paid on behalf of the XXXXXXXXXX and who is making this payment). ...
Technical Interpretation - Internal
22 March 2011 Internal T.I. 2011-0396221I7 - 45(2) Election - deemed no change in use
Yours truly, Sandy Parnanzone Manager, For Director Business and Partnerships Division Income Tax Rulings Directorate Legislative Policy & Regulatory Affairs Branch ...
Technical Interpretation - Internal
5 April 2011 Internal T.I. 2009-0342481I7 - Canada-France Tax Treaty, Article XX
Yours truly, Sherry Thomson for Director International Section I International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch FOOTNOTES Note to reader: Because of our system requirements, the footnotes contained in the original document are shown below instead: 1 We have attached an English translation of the terms of work for your reference. 2 Alternatively, in some situations, income paid to a student could be considered "a scholarship, fellowship or bursary" within the meaning of paragraph 56(1)(n) of the Act. ...
Technical Interpretation - Internal
13 October 2011 Internal T.I. 2011-0393101I7 - Transitional Tax Debit/Credit Calculation
13 October 2011 Internal T.I. 2011-0393101I7- Transitional Tax Debit/Credit Calculation Unedited CRA Tags Ss. 37(11) & 220(3.2), and Reg. 600 Principal Issues: Whether the election provided in variable "I" of the calculation of the "total federal balance" under subsection 48(4) of the Taxation Act, 2007 (Ontario) can be filed late or amended. ...
Technical Interpretation - Internal
2 June 2010 Internal T.I. 2010-0357921I7 - Replacement Property - Amalgamation
On XXXXXXXXXX, Subco 1 purchases XXXXXXXXXX % of the shares of an arm's length Canadian-controlled private corporation ("Subco 2"). 4. ...