Search - 深圳居住证 办理条件 最新政策
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Ruling summary
2022 Ruling 2021-0919101R3 - Ruling Letter -- summary under Subsection 106(2)
However, on the death of Daughter2, ½ of the Fund property had been distributed in accordance with the Fund terms to her issue. ...
Conference summary
10 October 2024 APFF Roundtable Q. 4, 2024-1028431C6 F - Production d’une déclaration de renseignements T1134 dans une situation donnée -- summary under Subsection 233.4(4)
CRA indicated that since Canco and Holdco each held the USco shares directly for a portion of their 2023 taxation year, each would be a reporting entity that was required to file a T1134 for their 2023 taxation year – however, as a related group with the same year end, and using the same functional currency, they could designate one of them as their representative to file a single T1134 information return with the required information for both. ...
Conference summary
10 October 2024 APFF Roundtable Q. 12, 2024-1028931C6 - Article 84.1 L.I.R. -- summary under Subparagraph 84.1(2)(a.1)(ii)
X's daughter purchased the shares from a person with whom she was dealing at arm's length … the ACB of those shares should not be reduced by paragraph 84.1(2)(a.1), for the purposes of section 84.1. ...
Technical Interpretation - Internal summary
25 April 2013 Internal T.I. 2013-0478511I7 F - Distribution à un commanditaire -- summary under Paragraph 96(1)(f)
. …. If, in the case described, there in fact is an allocation of capital gains of the SEC to its partners, we believe it would be difficult to maintain that they do not retain their character in the hands of the latter, including the Limited Partner.... ...
Technical Interpretation - External summary
5 June 2025 External T.I. 2025-1055221E5 - CCUS Factor - Power Purchase Agreements -- summary under Subparagraph A(b)(i)
After noting that the definition of qualified carbon capture expenditure – A(b)(i) in s. 127.44(1) refers to “the amount of energy expected to be produced for use in a qualified CCUS project over the project's total CCUS project review period”, CRA stated: [I]t is our view that there is no restriction on counting energy delivered through an electrical utility grid in determining “the amount of energy expected to be produced for use in a qualified CCUS project”. ...
Technical Interpretation - Internal summary
7 January 2011 Internal T.I. 2010-0387011I7 F - DPA dans une année prescrite -- summary under Subsection 152(4)
…[T]he CRA should not accept the adjustment request … as it would result in changes to the tax assessment for Year 1, which is a statute-barred year. ...
Technical Interpretation - Internal summary
25 February 2014 Internal T.I. 2013-0475161I7 - Whether USCo has a PE in Canada -- summary under Article 5
. … [G]eographic coherence [also] is required under the Treaty. ...
Ruling summary
2013 Ruling 2012-0449611R3 - single-wing butterfly reorganization -- summary under Subsection 186(1)
Holdco B Sub will be wound–up – and then dissolved. The two Notes will be set-off. ...
Ruling summary
2013 Ruling 2012-0449611R3 - single-wing butterfly reorganization -- summary under Distribution
Holdco B Sub will be wound–up – and then dissolved. The two Notes will be set-off. ...
Technical Interpretation - External summary
14 November 2013 External T.I. 2013-0499121E5 - upstream loan -- summary under Subsection 90(6)
. … Therefore…paragraph 248(28)(a)… applies to remedy the situation and avoid double taxation of the same amount. ...