Search - 水晶光电 行业地位 发展趋势

Thériault (613) 957-8953 ' l'attention de xxxxx Le 31 mai 1990 Madame, La présente est en réponse à votre lettre du 23 mars 1990 dans laquelle vous nous demandez notre opinion concernant l'application des dispositions de l'article 245 de la Loi de l'impôt sur le revenu (la "Loi") reativement à une série de transactions dont une était relative au paiement d'un dividende en actions en vertu du paragraphe 83(2) de la Loi par une corporation qui ne respecte pas les tests de solvabilité prévus à l'article 123.70 de la Loi sur les compagnies du Québec. ...

. • unapplied fertilizers- unapplied chemicals- fuel- parts for machinery- feed for livestock- seed grain- automobile gas purchased in bulk The term "inventory" as used in these paragraphs has the same meaning as it does throughout the Act. ...

XXX In Westcoast Energy Inc. v. the Queen [[1991] 1 C.T.C. 471] (91 DTC 5334) the court stated with respect to the definition of "reimbursement" found in subsection 12(1)(x) that "... the ordinary and legal meaning of the word reimbursement contemplates different legal relationships than that of parties in a law suit. ...

The District Office believes that the election is not available for the following reasons: (a) XXX (b) XXX (c) Both subsection 13(7.4) and 53(2.1) incorporate the phrase "... where a taxpayer has... received an amount that would... be included in income under paragraph 12(1)(x) in respect of the cost of a property (or a depreciable property) acquired by him... ...

One of the requirements for the application of paragraph 125(7)(d) of the Act is that the “... incorporated employee would reasonably be regarded as an officer or employee of the person... to whom or to which the services were provided but for the existence of the corporation...” on behalf of which he performed the services. ...

7 April 1991 Income Tax Severed Letter- Amending Joint Exploration Corporation Renouncements Unedited CRA Tags 66 OIL & GAS ISSUE REPORT O&G 09 RE: Audit Policy TITLE: Amending Joint Exploration Corporation Renouncements LEGISLATION: Sec 66's (10), (10.1), (10.2) and (10.3) ISSUES: Pursuant to a joint exploration corporation (JEC) agreement certain expenditures are renounced to a shareholder corporation. ...

7 October 1991 Income Tax Severed Letter- Small Business Corporation Unedited CRA Tags 186(2), 186(4), 248(1) Dear Sirs: Re: Interaction of subsections 186(2) & (4) This is in reply to your letter of August 29, 1991, wherein you request our views regarding the reference to subsection 186(4) of the Income Tax Act (the "Act") within the definition of "small business corporation" in subsection 248(1) of the Act. ...

7 January 1991 Income Tax Severed Letter- Payments under Ontario No-fault Insurance Program Unedited CRA Tags IT-365R2, IT-223 Dear Sirs: This is in reply to your letter of November 1, 1990 and further to our telephone conversation (Steeves/Weil) of January 4, 1991 concerning the tax treatment of certain types of payments which may be made under the “ Ontario No-Fault Insurance Program”. ...

. $ 99.72 It is our position that the full discount on Treasury Bills represents interest and, consequently, Treasury Bills are considered to be issued for an amount equal to their "principal amount" (as defined in subsection 248(1) of the Act) with the result that the condition set out in paragraph 16(3)(a) would not be satisfied. ...

You question our statement that reads, “... where the producer association is a taxable entity, tax could be exigible on the portion of the interest paid by the federal government”. ...