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Technical Interpretation - Internal

22 January 2016 Internal T.I. 2015-0586673I7 - Self-governing First Nations in the Yukon and BC

A "Yukon Indian Person", as defined in Chapter 1 of the UFA, is a person enrolled under one of the Yukon First Nation Final Agreements in accordance with criteria established in Chapter 3 Eligibility and Enrollment. ...
Technical Interpretation - Internal

15 March 2016 Internal T.I. 2014-0549701I7 - Obligation of Crown corporations to file a T106

Requirement to file a T106 The requirement to file form T106 Information return of non-arm’s length transactions with non-residents for a particular taxation year is governed by section 233.1, which falls under Part XV of the Act. ...
Technical Interpretation - Internal

3 February 2011 Internal T.I. 2008-0301631I7 - tuition tax credit - University outside Canada

" and further stating that it includes " the members of this collectively". ...
Technical Interpretation - Internal

24 October 2011 Internal T.I. 2011-0404731I7 - XXXXXXXXXX -Paragraph 149(1)(l)

The funds for these expenses must come from "amounts contributed to the fund on behalf of the XXXXXXXXXX " (it is not clear to us what amount is paid on behalf of the XXXXXXXXXX and who is making this payment). ...
Technical Interpretation - Internal

22 March 2011 Internal T.I. 2011-0396221I7 - 45(2) Election - deemed no change in use

Yours truly, Sandy Parnanzone Manager, For Director Business and Partnerships Division Income Tax Rulings Directorate Legislative Policy & Regulatory Affairs Branch ...
Technical Interpretation - Internal

5 April 2011 Internal T.I. 2009-0342481I7 - Canada-France Tax Treaty, Article XX

Yours truly, Sherry Thomson for Director International Section I International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch FOOTNOTES Note to reader: Because of our system requirements, the footnotes contained in the original document are shown below instead: 1 We have attached an English translation of the terms of work for your reference. 2 Alternatively, in some situations, income paid to a student could be considered "a scholarship, fellowship or bursary" within the meaning of paragraph 56(1)(n) of the Act. ...
Technical Interpretation - Internal

13 October 2011 Internal T.I. 2011-0393101I7 - Transitional Tax Debit/Credit Calculation

13 October 2011 Internal T.I. 2011-0393101I7- Transitional Tax Debit/Credit Calculation Unedited CRA Tags Ss. 37(11) & 220(3.2), and Reg. 600 Principal Issues: Whether the election provided in variable "I" of the calculation of the "total federal balance" under subsection 48(4) of the Taxation Act, 2007 (Ontario) can be filed late or amended. ...
Technical Interpretation - Internal

2 June 2010 Internal T.I. 2010-0357921I7 - Replacement Property - Amalgamation

On XXXXXXXXXX, Subco 1 purchases XXXXXXXXXX % of the shares of an arm's length Canadian-controlled private corporation ("Subco 2"). 4. ...
Technical Interpretation - Internal

18 January 2011 Internal T.I. 2010-0390971I7 - Wind Turbines and ITCs

Under subsection 4600(2) of the Regulations, property is "prescribed machinery and equipment" if, inter alia, it is depreciable property of the taxpayer that is "... ...
Technical Interpretation - Internal

3 August 2010 Internal T.I. 2010-0369281I7 - Clergy residence deduction

It is our understanding that the mission of the Entity is "XXXXXXXXXX " In Zylstra Estate v The Queen, 94 DTC 6687, Mackay, J. made the following comments when concluding why The Ontario Bible College and Ontario Theological Seminary ("OBC") and the Institute of Christian Studies ("ICS") were not considered a religious order for the purpose of claiming a clergy residence deduction pursuant to paragraph 8(1)(c): "There are two principal considerations which lead me to conclude that neither OBC nor ICS is a "religious order" within the intention of paragraph 8(1)(c). ...

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