Search - 水晶光电 行业地位 发展趋势

Facts 1.     Corporation A, a Canadian corporation and a private corporation is a wholly-owned subsidiary of Corporation N. The expression "Canadian corporation" and "private corporation" as referred to here and subsequently have the meaning assigned in paragraphs 89(1) (a) and 89(1)(f) of the Act, respectively. 2.     Corporation N, all of whose shares are held by Corporation 8, is a non-resident corporation for purposes of the Act. 3.      ...

6 November 1989 Administrative Letter 58546 F- Taxation of Disability Income Benefits Unedited CRA Tags 6(1)(f) 19(1) File No. 5-8546   A. Humenuk   (613) 957-2135 November 8, 1989 Dear Sirs: Re:  Taxation of Disability Income Benefits Health and Welfare Plan We are responding to your letter of August 17, 1989, concerning the taxation of disability income benefits received from a health and welfare trust. ... However, in the unique situation described in your letter, we would be prepared to consider that the advance was not a form of subsidization provided that; 1)     the situation arose inadvertently, 2)     the advance was in fact, a genuine loan in which bona fide arrangements were made at the time the loan was made for repayment within a reasonable time, and 3)     the contribution level for the plan in the deficit position is reset to a level which would adequately fund the plan. ...

5 July 1990 Administrative Letter 901016 F- Computation of Cumulative Net Investment Loss Unedited CRA Tags 15(2), 20(1)(j), 110.6(1) cumulative net investment loss 24(1) 901016   M. Eisner   (613) 957-2138 Attention:  19(1) EACC9464 July 5, 1990 Dear Sirs: This is in reply to your letter of May 28, 1990 concerning the effect of a deduction under paragraph 20(1)(j) of the Income Tax Act (the "Act") and an income inclusion under subsection 15(2) of the Act on the "cumulative net investment loss"  account as defined in subsection 110.6(1) of the Act. ...

.- Adverse Decision Unedited CRA Tags 18(1)(1)   November 15, 1989 Mrs. ... Tremblay Current Amendments and Acting Director Regulations Division Appeals & Referrals Division R.D. ...

5 September 1989 Administrative Letter 3206- Version française d'une modification au Réglement de l'impot sur le revenu Unedited CRA Tags n/a   Le 5 septembre 1989 Mr. ... Burnett/ 957-2078   F-3206 Objet: Règlement de l'impôt sur le revenu Par la présente je réponds à votre note de service du 22 août 1989 concernant le sujet ci-dessus. ...

17 October 1989 Administrative Letter 58656 F- Lump-sum Payment under RRSP to Deceased Annuitant's Estate Unedited CRA Tags 104(27), 56(1)(a)(i), 60(j) 19(1) File No. 5-8656   F. Francis   (613) 957-3496 October 17, 1989 Dear Sirs: This is in reply to your letter of September 6, 1989, wherein you requested our opinion in respect of a specific proposed transaction concerning a proposed lump sum payment under a registered pension plan to the deceased's estate. ...

16 October 1989 Administrative Letter 58636 F- Pension Benefit Rollover to a Spousal RRSP Unedited CRA Tags n/a 19(1) File No. 5-8636   A.B. Adler   (613) 957-8962 October 16, 1989 Dear Sirs: This is in reply to your letter of August 30, 1989 concerning your client, 19(1) 24(1) There is provision, under proposed legislation, for the direct transfer of a lump sum amount from an RPP to an RRSP for the benefit of the spouse or former spouse of a RPP member where the amount is transferred pursuant to a court order or written agreement relating to a division of property on marriage breakdown.  ...

18 October 1990 Administrative Letter 901846 F- Employee Benefit of Counselling Services Unedited CRA Tags 56(1)(a)(ii), 248(1) retiring allowance 19(1) 901846   M. Eisner   (613) 957-2138 October 18, 1990 19(1) This is in reply to your letter of July 22, 1990 concerning the tax treatment of  24(1) As we understand it  24(1) In your letter, you enclosed a copy of a Press Release issued by the Department of Finance in 1988 describe proposed changes to the Income Tax Act clarifying that certain counselling services provided for employees by their employers will not be treated as taxable benefits. ...

23 March 1990 Administrative Letter 59356 F- Calculation of Minimum Amount Under RRIF Unedited CRA Tags 146.3(1) minimum amount 19(1) File No. 5-9356   F. Francis   (613) 957-3496 March 23, 1990 Dear Sirs: This is in reply to your letter of December 22, 1989, and further to our telephone conversation on February 8, 1990, wherein you requested a technical interpretation in respect of the calculation of the minimum amount under paragraph 146.3(1)(b.1) of the Income Tax Act (the "Act"). ...

30 January 1990 Administrative Letter 59426 F- Transfer of Retiring Allowances Unedited CRA Tags 60(j.1) 19(1) File No. 5-9426   Maureen Shea-DesRosiers   (613) 957-8953 January 30, 1990 Dear Sirs: Re:  Paragraph 60(j.1) of the Income Tax Act (the "Act") This is in reply to your letter of January 19, 1990 wherein you requested a technical interpretation on the applicability of paragraph 60(j.1) of the Income Tax Act (the "Act") in the following situation: 24(1) It would appear that the above-described situation represents a proposed factual situation. ...