Search - 江西农大 毛瑢
Results 7431 - 7440 of 8063 for 江西农大 毛瑢
Article Summary
Sabrina Wong, Sania Ilahi, "Tax Implications of Asset Securitizations", 2015 CTF Annual Conference Report -- summary under Paragraph 1100(2.2)(f)
. … [L]eased equipment that is acquired with the intention of immediately selling it to the limited partnership may not be considered to be depreciable property. ...
Article Summary
Ian Bradley, Denny Kwan, Dian Wang, "Is The Back-to-Back Withholding Tax Regime an Effective Anti-Treaty-shopping Measure?", Canadian Tax Journal, (2016) 64:4, 833-58 -- summary under Paragraph 212(3.9)(b)
In order to rely on the exemption from withholding tax under the Canada-US treaty [fn 61: … at article XII(3)(b)] the Canadian requests a representation from the licensor that there is no licensing arrangement that may be caught by the connection test in the back-to-back rules. ...
Article Summary
Elie Roth, Tim Youdan, Chris Anderson, Kim Brown, "Taxation of Trusts Resident in Canada", Chapter 3 of Canadian Taxation of Trusts, (Canadian Tax Foundation), 2016. -- summary under (2)-(41)
Putter … [F.n.168 2014 MBQB 254] appear to support the CRA's position. ...
Article Summary
Elie Roth, Tim Youdan, Chris Anderson, Kim Brown, "Taxation of Trusts Resident in Canada", Chapter 3 of Canadian Taxation of Trusts, (Canadian Tax Foundation), 2016. -- summary under Subsection 118.1(6)
[F.n.259 – CRA document no. 2013-0486701E5, July 15, 2013.] For example, assume that a trust holds private company shares with a fair market value of $1 million and a $100,000 cost, and it wants to donate the shares to a private foundation. ...
Article Summary
Elie Roth, Tim Youdan, Chris Anderson, Kim Brown, "Taxation of Trusts Resident in Canada", Chapter 3 of Canadian Taxation of Trusts, (Canadian Tax Foundation), 2016. -- summary under Subsection 104(24)
[F.n.283 – Cindy Radu and Siân Matthews, "Trust Administration—Best Practices," in 2010 Atlantic Provinces Tax Conference (Toronto: Canadian Tax Foundation, 2010), 4A:l-20. ...
Article Summary
Lorenzo Bonanno, Guy Buckley, "Limited Liability Partnerships", Canadian Tax Highlights, Vol. 25, No. 2, February 2017, p. 7 -- summary under Paragraph 40(3.14)(a)
. … Full-shield protection generally protects a partner against most partnership liabilities. ...
Article Summary
Elie Roth, Tim Youdan, Chris Anderson, Kim Brown, "Classification of Trusts for Income Tax Purposes", Chapter 2 of Canadian Taxation of Trusts (Canadian Tax Foundation), 2016. -- summary under Paragraph 20(1)(r)
[fn 220: … 2007-025985117… 2010-0388761R3] Distributions to Canadian-resident employees from the RCA are taxed in the year in which they are received under paragraph 56(1)(x), and are subject to withholding tax under paragraph 212(1)(j),… ...
Article Summary
Joint Committee, "Proposed Changes to the Voluntary Disclosure Program Announced June 9, 2017", 8 August 2017 Joint Committee Submission to Finance respecting the Voluntary Disclosure Program (“VDP”) -- summary under Subsection 220(3.1)
Large corp,/ transfer-pricing exclusion (pp. 8-10) Furthermore, errors by large corporations typically are attributable to the number and complexity of the tax-reporting issues faced by them, so that their exclusion would violate fundamental principles of fairness – as does blanket denial of relief to taxpayers respecting transfer pricing errors. ...