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Miscellaneous severed letter

7 December 1990 Income Tax Severed Letter - Factors to be Considered in Establishing Whehter Particular Shares were Acquired in the Ordinary Course of Business

The DNR has made two public comments on the issue: (a) 1980 Conference Report: Q.23 “... shares issued on the incorporation of a wholly-owned subsidiary would not as a rule be in the ordinary course of business.” ...
Miscellaneous severed letter

7 January 1991 Income Tax Severed Letter - Non-profit Organizations

Paragraph 11 of IT-496, suggests that enabling documents may provide that all of the “... assets and accumulated income are to be transferred to an organization with similar objects that qualifies for exemption pursuant to paragraphs 149(1)(f) or (l) of the Act”. ...
Miscellaneous severed letter

7 June 1991 Income Tax Severed Letter - Health and Welfare Trust

As stated in paragraph 1 of IT-85R2, in order to qualify as a Health & Welfare Trust, the benefit programs funded through the trust must be restricted to one or more of the following plans: a) a private health services plan, b) a group sickness or accident insurance plan, or c) a group term life insurance police. ...
Miscellaneous severed letter

7 October 1990 Income Tax Severed Letter - Disposition of Goodwill

Comments With regard to your first question, subsection 85(6) of the Act requires that an election made under subsection 85(1) of the Act "... be made on or before the earliest of the days on or before which any taxpayer making the election is required to file a return of income pursuant to section 150 of the Act for the taxation year in which the transaction to which the election relates occurred. ...
Miscellaneous severed letter

7 February 1991 Income Tax Severed Letter - Automobile Allowances

., using an appropriate per-kilometre rate applied to all business kilometres driven by the employee), that is not otherwise “deemed” an unreasonable allowance [subparagraphs 6(1)(b)(x) & (xi)], then deductions at source from the allowance would not be required. ...
Miscellaneous severed letter

7 May 1991 Income Tax Severed Letter - Tax on Large Corporations

In particular, you asked whether the deeming provision in the postamble of section 8600 of the Regulations, which reads, in part, "... where a corporation's taxable income for a taxation year is nil, it shall, for the purposes of this section, be deemed to have a taxable income for that year of $1,000" applies to both items C and B or only item C in the algebraic formula in section 8600 of the Regulations. ...
Miscellaneous severed letter

9 March 1992 Income Tax Severed Letter 9200445 - NPO - Subsidiary Owned By

Holloway Toronto, Ontario (613) 957-2104 Attention: XXX March 9, 1992 Dear Sirs: Re: Paragraph 149(1)(1) of the Income Tax Act (the “Act”) & IT496 This is in reply to your letter dated December 23, 1991, requesting our interpretation in respect of the activities of your client the XXX and whether a corporation owned by the XXX qualifies as an non-profit organization as defined in paragraph 149(1)(1) of the Act. ...
Miscellaneous severed letter

9 October 1992 Income Tax Severed Letter 9230057 - Royalty to Non-resident to Distribute Films

XII RULINGS TAX SEMINAR CENTRAL REGION OCTOBER 14 & 15, 1992 ROYALTIES EXEMPTION- MEANING OF IN RESPECT OF PRODUCTION OR REPRODUCTION Subparagraph 212(1)(d)(vi) exempts certain copyright related payments in respect of the production or reproduction of any literary, dramatic, musical or artistic work. ...
Miscellaneous severed letter

9 September 1992 Income Tax Severed Letter 9206815 - Rental Income of Non-resident

Document Disclosed Pursuant to The Access To Information Act Document Divulgué en vertu de la loi sur l'accès à l'information In addition to Information Circular 70-6R2 and IT-393R, we have attached the 1991 General Tax Guide and Return Federal Income Tax: " Non-residents and deemed residents of Canada" and the 1991 Supplementary Guide: "Rental Income Tax Guide" for your information. ...
Miscellaneous severed letter

7 October 1992 Income Tax Severed Letter 9229926 - RRSP Home Buyers Plan

7 October 1992 Income Tax Severed Letter 9229926- RRSP Home Buyers Plan Unedited CRA Tags 146.01 October 7, 1992 Business & Property Income Deferred Income and Exempt Organizations Section Plans Section Business and General Division Financial Industries Division Attention: Ernie Wheeler D. ...

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