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Article Summary
Michael N. Kandev, Sandra Slaats, "Recent Developments in the Foreign Affiliate Area", 2015 Annual CTF Conference paper -- summary under Corporation
[f.n. 23: … 2006-021645117] Effectively taxpayers have since been faced with a "don’t ask, don’t tell" situation. ...
Article Summary
Michael N. Kandev, Sandra Slaats, "Recent Developments in the Foreign Affiliate Area", 2015 Annual CTF Conference paper -- summary under Section 96
[f.n. 23: … 2006-021645117] Effectively taxpayers have since been faced with a "don’t ask, don’t tell" situation. ...
Article Summary
Paul Barnicke, Melanie Huynh, "Earnings of Disregarded US LLC", Canadian Tax Highlights, Vol. 25, No. 2, February 2017, p. 5 -- summary under Subparagraph (a)(iii)
Treatment where previous Code deduction was less than maximum ITA deduction (pp. 5-6) [I]t is therefore unclear whether – if the Act provided for a larger deduction than US tax law did for the years in question—the shortfall leads to a retroactive downward adjustment to the earnings computed under regulation 5907(l)(a)(iii): regulation 5907(2.03)(b) deems maximum deductions to have been claimed in prior taxation years…. ...
Article Summary
N.E. Palmer, Bailment, Second Ed., The Law Book Co. Ltd, 1991 -- summary under Subsection 204(3)
& W. 481 at 486; 153 E.R. 200 at 202 by Rolfe B., who went on to remark: "there does not seem to be any solid ground of distinction, in this respect, between a bailment by way of pawn and any other bailment. ...
Article Summary
Michael N. Kandev, "Canada Expands Back-to-Back Regime: Examining the Character Substitution Rules", Tax Notes International, June 19, 2017, p.1087 -- summary under Paragraph 212(3.6)(b)
. … Mobil Oil Canada Ltd. v. R., 2001 FCA 333 adopted the following meaning…: …“Compensation for the use of property, usually copyrighted material or natural resources, expressed as a percentage of receipts from using the property or as an account per unit produced….] ...
Article Summary
Hugh Chasmar, "Corporate Class Funds", Canadian Tax Highlights, Vol. 25, No. 8, August 2017, p. 6 -- summary under Subsection 131(4.1)
. … Subsection 131(4.1) requires…[i]n effect [that] portfolios underlying the terminating and surviving funds must be identical before the shareholders qualify for a tax-deferred rollover. ...
Article Summary
Nigel P.J. Johnston, Roger E. Taylor, "Taxation of Hedges and Derivatives: Recent Developments", 2016 Conference Report (Canadian Tax Foundation), 13:1-36 -- summary under Futures/Forwards/Hedges
. … In contrast, a dynamic hedge involves adjusting the hedge as the underlying security changes in value throughout the life of the contract. ...
Article Summary
Peter Lee, Paul Stepak, "PE Investments in Canadian Companies", draft 2017 CTF Annual Conference paper -- summary under Subsection 212.3(1)
. … [I]f a. non-87(11) amalgamation is necessary, what is the FAD consequence? ...
Article Summary
David H. Sohmer, "Do Shares of an American Company Credited to an Account with a Canadian Broker constitute ‘Specified Foreign Property’?", The Canadian Taxpayer, August 10, 2018. Vol. xl, No 16, p. 121 -- summary under Paragraph (c)
. … In 2006 Ontario became the first Canadian province to enact a securities transfers act based on Revised UCC Article 8. ...
Article Summary
Nik Diksic, Sabrina Wong, "Cross-Border Lending Practices", 2017 CTF Annual Conference draft paper -- summary under Paragraph 212(3.1)(d)
Nik Diksic, Sabrina Wong, "Cross-Border Lending Practices", 2017 CTF Annual Conference draft paper-- summary under Paragraph 212(3.1)(d) Summary Under Tax Topics- Income Tax Act- Section 212- Subsection 212(3.1)- Paragraph 212(3.1)(d) Cannot benefit from ultimate funder withholding rate if immediate funder rate is higher (p. 11) Consider … where NR1 (treaty country [with 10% withholding rate]) has funded CA through NR2 (non-treaty country) and NR3 ([held by NR2 and in a] treaty country [with 0% withholding rate]). ...