Search - 江苏苏美达轻纺国际贸易有限公司 关税政策 最新动态

Clause 4.5 of the Plan provides that the teacher may at his/her option, on one occasion only, postpone the leave for one year.       ... The Plan should indicate clearly that it is not established to provide benefits to the employees on or after retirement. 7.     The Plan must specify that the minimum leave of absence shall be for a period of six (6) months. 8.      ...

Hillier, A/Director Directorate   R.C. O'Byrne E. Pringle 957-2126   File No. 7-4494 Subject: Treaty Exempt Income and Alternative Minimum Tax This is in reply to your memorandum of November 7, 1989 in which you asked for our views on the application of the minimum tax rules of the Income Tax Act (the "Act") to a treaty exempt capital gain. The situation 1.     A United States ("U.S.") resident disposed of a property located in Canada during 1988. 2.      ... Income Tax Convention (1980) (the "Convention"). 3.     The U.S. resident filed a 1988 Canadian Income Tax Return wherein he reported the taxable portion of the capital gain and an equal offsetting deduction under subparagraph 110(1)(f)(i) of the Act. 4.      ...

A.      Mr. A exercises the option after the dissolution of their marriage. ... A pursuant to the contractual agreement. 2.     At the time of the dissolution of the marriage, Mr. ... In this regard, rights arising out of a marriage would, in our view, be rights arising from a marriage contract and/or rights arising out of provisions in the family law legislation of the applicable province. 2      In this situation, it is our view that the transfer of the capital property from Mr. ...

B each own 50% of a Canadian Controlled Private  Corporation. 2.     Mr. ... B are not related. 3.     The corporation is a small business corporation and is very profitable. 4.      ... B. 8.     There is no written documentation that requires Mr. A to gift Mr. ...

18 October 1989 Ministerial Correspondence 58074 F- Foreign Accrual Property Income and Currency Swaps Unedited CRA Tags 95(2)(b)(i)(A), 15(1) 19(1) File No. 5-8074   D.Y. ... The fact situation that you have presented is as follows: 1.     A Canadian financial institution ("Canco") has significant U.S. dollar liabilities on the books. 2.      ... It is conceivable that the transactions may result in property income to FA or may be on account of capital. 2)     Paragraph 95(2)(b) of the Act may apply. ...

27 October 1989 Ministerial Correspondence 58274 F- Automobile Allowances Unedited CRA Tags 6(1)(b)(vii.1), 6(1)(b)(v), 6(1)(b)(x), 6(1)(b)(xi) 19(1) File No. 5-8274   A. Humenuk   (613) 957-2135 October 27, 1989 Dear 19(1) Re:  Automobile Allowances Your letter of January 20, 1989, concerning the taxation of automobile allowances paid to various employees of your company has been referred to us for reply.  ... Facts The facts of the situation as we understand them can be summarized as follows: 24(1) The Department's Position Generally, an automobile allowance paid to an employee will be excluded from income if: (i)      the allowance is not in excess of a reasonable amount (subparagraph 6(1)(b)(vii.1) of the Act) or in the case of an employee employed in connection with selling property or negotiating contracts for his employer, is a reasonable amount (subparagraph 6(1)(b)(v) of the Act); (ii)      the allowance is based solely in the number of kilometres the vehicle is used to earn employment income (subparagraph 6(1)(b)(x) of the Act) and (iii)      the employee is not reimbursed for any expense for the same use (kilometres) for which the employee is paid a travel allowance (subparagraph 6(1)(b)(xi) of the Act). ...

24 October 1990 Ministerial Correspondence 58954 F- General Anti-avoidance Rule and IC 88-2 Unedited CRA Tags 245 24(1) 5-8954    S.J. ... In particular you asked the following: (a)     To what sources will the Department look to discover Parliament's intention as to the consequences of specific provisions of the Act? (b)     Would the acquisition of shares of a profitable corporation by a loss corporation be subject to subsection 245(2) of the Act? ...

27 April 1990 Ministerial Correspondence 59514 F- Unpaid Remuneration Unedited CRA Tags 78(4) 19(1) File No. 5-9514   R.B. Day   (613) 957-2136 April 27, 1990 19(1) We are writing in reply to your letter of January 23, 1990, wherein you requested our opinion regarding the interpretation of subsection 78(4) of the Income Tax Act in the following situations: 1.      ... B.      The Department's position regarding payments by way of cheque is that the amount of the cheque is income to the taxpayer at the time it is received form a person who is indebted to the taxpayer and certain other conditions are fulfilled.  ...

9 June 1989 Ministerial Correspondence 73534 F- Application of General Anti-avoidance Rule Unedited CRA Tags 245, 248(10)   June 9, 1989 Audit Programs Directorate Specialty Rulings Directorate   Wyman W. ... " was stated as follows at the 1988 CTF Conference:      A series of transactions determined without reference to subsection 248(10) would not include related transactions carried out in contemplation of the series.  ... HiltzDirectorReorganization and Non-Resident DivisionSpecialty Rulings Directorate Legislative and IntergovernmentalAffairs Branch Attachments c.c.      ...

26 January 1990 Ministerial Correspondence 58964 F- Withholding Tax Requirements Unedited CRA Tags 212(1)(d)(i) 19(1) File No. 5-8964   R.C. O'Byrne   (613) 957-2126 January 26, 1990 Dear Sirs: This is in reply to your letter of October 23, 1989 wherein you requested our opinion concerning withholding tax requirements in the following hypothetical situation: (1)     The distributor is a taxable Canadian corporation. (2)     The distributor enters into a distribution agreement ("the Agreement") with a non-resident manufacturer of computer software. (3)     The Agreement allows the distributor to import and distribute software products from the non-resident manufacturer. (4)     The non-resident manufacturer is not resident in Canada, and is not considered to be carrying on business in Canada, pursuant to the provisions of the Act. (5)     Under the terms of the Agreement, the distributor's relationship with the manufacturer is that of an independent contractor.  The distributor's appointment only grants the distributor a right to distribute the manufacturer's products to authorized dealers, and does not in any way transfer any right, title or interest in any of the manufacturer's products to the distributor. (6)     The distributor has no tight to duplicate, cope, or change the software in any manner.  ...