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Miscellaneous severed letter

25 June 1985 Income Tax Severed Letter A-1158 - [Subsection 70(5.3) of the Income Tax Act]

Diguer, ADM Policy & Systems Branch 70(5.3) 148(9)(b) ...
Miscellaneous severed letter

4 November 1980 Income Tax Severed Letter

Campbell: We wrote to you on April 4, 1979 to advise you that we would treat amounts paid under the Public Service Superannuation Act "... as a death benefit", as death benefits to the recipients rather than as pension benefits although the amount is received out of a pension fund or plan. ...
Miscellaneous severed letter

18 October 1985 Income Tax Severed Letter A-1643 - [Employee housing loans]

By way of illustration, you have provided us with the following example Assume Employees' cash down payment $ 35,000 Interest-free and low-interest loans 145,000 Total purchase price- 1981 180,000 Unrealized loss (50,000) Current market value 130,000 As a result of the proposal, the interest-free and low-interest employee loans of $145,000 would be cancelled. ...
Miscellaneous severed letter

12 December 1985 Income Tax Severed Letter

Her Majesty The Queen cited 85 DTC 5336, the Court ruled that, in the case of units mounted to vehicles, "... the property fits within two categories. ...
Miscellaneous severed letter

11 June 1985 Income Tax Severed Letter

Muirhead Chief Non-Resident, Business & Property Income Canada-United States Income Tax Convention Q. ...
Miscellaneous severed letter

24 June 1987 Income Tax Severed Letter

Clemens Chief, Basic Files & Business Audit RE: This is in reply to your memorandum of May 11, 1987 in which you requested our opinion regarding the timing of reporting income earned by a bulk sales dealer under an incentive commission plan established by XXXXXXXX the "Plan"). ...
Miscellaneous severed letter

17 October 1985 Income Tax Severed Letter

17 October 1985 Income Tax Severed Letter DATE October 17, 1985 To- Audit Directorate Policy & Systems Branch FROM- Corporate Rulings Director Legislative and Intergovernmental Affairs Branch K.H. ...
Miscellaneous severed letter

21 February 1984 Income Tax Severed Letter

As we read that subsection it catches a taxpayer upon an amount calculated by reference to "... the fair market value, at the time of its acquisition by a taxpayer described in any of paragraphs 205(a) to (f), of a foreign property... ...
Miscellaneous severed letter

12 August 1985 Income Tax Severed Letter B-6190 - [Salesman's Expenses]

In other words, the fact that a salesman may not meet the requirements for the application of subparagraph 8(1)(i)(ii) of the Act ("... salary to an assistant... the payment of which... was required by the contract of employment") does not limit an employee- salesman from claiming as an expense the payment of salary to an assistant under paragraph 8(1)(f) of the Act ("under the contract of employment was required to pay his own expenses") if he otherwise qualifies under that paragraph and the amount paid is reasonable. ...
Miscellaneous severed letter

3 December 1985 Income Tax Severed Letter

Mail Control & OPRU Taxpayer's file XXXX Your letter of October 10, 1985, regarding the taxation of oil royalties has been forwarded to me for response. ...

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