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Technical Interpretation - Internal summary

2 February 2010 Internal T.I. 2009-0345741I7 F - Programme d'aide financière d'urgence ("PAFU") -- summary under Paragraph 56(1)(u)

. Since the PAFU is primarily intended to meet the needs of people affected by an emergency situation, we believe that the financial assistance that will be paid by the MESS in the form of a lump sum to cover living expenses and/or specific costs will be paid after a review of needs by the MESS, without the MESS conducting a means or income test for people affected by an emergency situation. ...
Technical Interpretation - Internal summary

22 December 2009 Internal T.I. 2009-0343331I7 F - Determination of CCPC Status -- summary under Canadian-Controlled Private Corporation

Consequently, there is no provision in provincial legislation affecting Part IA corporations for the power of the majority shareholder to control the election of the board of directors to be limited or altered by means of a USA. ...
Technical Interpretation - Internal summary

10 January 2008 Internal T.I. 2007-0254551I7 F - Provision relative à certaines marchandises -- summary under Subparagraph 20(1)(m)(i)

The fact that the franchisor does not itself deliver the goods does not invalidate the application of subparagraph 20(1)(m)(i) ...
Technical Interpretation - Internal summary

11 October 2017 Internal T.I. 2017-0719181I7 F - Agreement in writing -- summary under Paragraph (g.4)

11 October 2017 Internal T.I. 2017-0719181I7 F- Agreement in writing-- summary under Paragraph (g.4) Summary Under Tax Topics- Income Tax Act- Section 66.1- Subsection 66.1(6)- Canadian exploration expense- Paragraph (g.4) pre-production mine development expenses that qualify under CEE (g.4) need not qualify under (g.3) Corporation X, which is a principal-business corporation, issues a flow-through share under a written agreement entered into on December 31, 2012, renounces its Canadian exploration expenses under the look-back rule and enters into a written agreement dated June 20, 2013 with a subcontractor for the incurring of pre-production mine development expenses, with the work (entailing payments of Corporation X of $2 million) ending on December 31, 2013. ...
Technical Interpretation - Internal summary

24 October 2006 Internal T.I. 2006-0203901I7 F - Avantage automobile -- summary under Paragraph 6(1)(a)

. In finding that this exception to a taxable benefit was inapplicable, CRA stated: According to the CRA, a pick-up point is a common place specifically designated by the employer for that purpose to which all employees must go. ...
Technical Interpretation - Internal summary

16 May 2005 Internal T.I. 2005-0119061I7 F - Montant d'aide-actions -- summary under Paragraph (a)

Since the loan from M Co is assistance that is required to be included in Prod Co's income under paragraph 12(1)(x), the conversion of the loan by M Co into shares of Prod Co at the end of the production would not engage the application of subsection 80(2). ...
Technical Interpretation - Internal summary

16 August 2017 Internal T.I. 2015-0622751I7 - Part XIII Tax on Benefit to Non-resident -- summary under Subsection 160(1)

Did the interest-free loan generate Part XIII tax and, if so, who had the obligation to collect and remit the tax and how could it be collected? ...
Technical Interpretation - Internal summary

7 February 2018 Internal T.I. 2017-0711961I7 - Withholding on RCA payment to partnership -- summary under Paragraph 153(1)(q)

. Since Schedule I does not address this situation, the Payment is subject to subsection 106(1). ...
Technical Interpretation - Internal summary

17 April 2018 Internal T.I. 2018-0739141I7 - Amending a statute barred partnership return -- summary under Subsection 152(4)

. Whether the Minister agrees to the request would depend on the particular facts of the situation. ...
Technical Interpretation - Internal summary

6 June 2003 Internal T.I. 2003-0183437 - Distributions from non-res trust -- summary under Subsection 104(13)

. The income of the Trust for the XXXXXXXXXX taxation year would be computed under Canadian rules pursuant to section 250.1 and would include the $XXXXXXXXXX dividends received. ...

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