Search - 赤峰 二中 初中学区划分 2002

PRINCIPAL ISSUES: Clarifying position taken in 2010-036838 [] with the following: a) Can each parent claim a child under line 305 as an equivalent-to-spouse, where there is a “set off” child support payment? ... Robertson, CMA April 27, 2011 Dear XXXXXXXXXX: Re: Eligible Dependent Credit (EDC), [formerly known as Equivalent-to-Spouse Credit]- Child Support Payments with “Set off” This letter clarifies issues addressed in our file 2010-036838 []. ... Written confirmation of the tax implications inherent in particular transactions may only be provided by this Directorate where the transactions are proposed and are the subject matter of an advance income tax ruling submitted in the manner set out in Information Circular 70-6R5, Advance Income Tax Rulings, (IC 70-6R5) dated May 17, 2002. ...

As indicated in Re Rispin ((1912) 25 O.L.R. 633, 2 D.L.R. 644; affirmed 46 S.C.R. 649, 8 D.L.R. 756: The cases bearing upon similar questions [...] are numerous, and one might even say sometimes embarrassing, if not conflicting. [...] ... The instructions given for the opening of the account were as follows: "Look at my account current, and [...] make a purchase in some public stock [...] for my boy Lionel Eldred, who is this day twelve months old. Let it be in my own name and in my wife's, [...] in trust for Lionel Eldred Smith". ...

Written confirmation of the tax implications inherent in particular transactions are given by this Directorate only where the transactions are proposed and are the subject matter of an advance ruling request submitted in the manner set out in Information Circular IC-70-6R5 [Information Circular 70-6R5] dated May 17, 2002. ... However, the taxpayer should be prepared to explain the reason(s) for the delay in his or her attempt to sell the property in order that a determination be made as to whether resulting costs were in fact paid “... as or on account of moving expenses incurred in respect of an eligible relocation...”, as required under subsection 62(1) of the Act. If, for example, it is determined that the taxpayer's intention was to hold the property for investment purposes or to hold it until the market improved, selling costs will generally not be considered “... amounts paid by the taxpayer as or on account of moving expenses incurred in respect of an eligible relocation.” ...

XXXXXXXXXX) This is in reply to your emails dated XXXXXXXXXX in which you requested amendments to the Advance Income Tax Ruling letter issued to the above-referenced taxpayer on XXXXXXXXXX, 2006 (document # 2006-020105 [], the “Ruling”). ... The opinion and the ruling in the Ruling as modified in this letter are given subject to the limitations and qualifications set forth in Information Circular 70-6R5 issued on May 17, 2002. ...

Partnership1 was formed in XXXXXXXXXX to XXXXXXXXXX; • a XXXXXXXXXX% limited partnership interest in Partnership2, the FMV of which is estimated at approximately $XXXXXXXXXX as at XXXXXXXXXX. ... The federal business number of the parties referred to herein, the location of the tax services office and taxation centre where their returns are filed, and the address of their head office are as follows: XXXXXXXXXX • Business Number: XXXXXXXXXX • Tax Services Office: XXXXXXXXXX • Taxation Centre: XXXXXXXXXX • Address: XXXXXXXXXX XXXXXXXXXX • Business Number: XXXXXXXXXX • Tax Services Office: XXXXXXXXXX • Taxation Centre: XXXXXXXXXX • Address: XXXXXXXXXX PURPOSES OF THE PROPOSED TRANSACTIONS 45. ... The above rulings are given subject to the limitations and qualifications set forth in Information Circular 70-6R5 issued on May 17, 2002, and are binding on the CRA provided that the proposed transactions are completed before XXXXXXXXXX. ...

La Convention prévoit que SPXY encaissera toutes les recettes, paiera toutes les dépenses d'opération et recevra une somme de 15 % des revenus d'opération à titre de frais de gestion. ... Nos commentaires La situation décrite dans votre demande nous apparaît être une situation réelle et, tel que mentionné au paragraphe 22 de la Circulaire d'information 70-6R5 [Information Circular 70-6R5] du 17 mai 2002, la Direction ne donne généralement pas d'opinion écrite concernant des opérations projetées autrement que par voie de décision anticipée. ... Ces commentaires ne constituent pas des décisions anticipées en matière d'impôt sur le revenu et, tel qu'il est mentionné au paragraphe 22 de la Circulaire d'information 70-6R5 [Information Circular 70-6R5] du 17 mai 2002, ne lient pas l'ADRC à l'égard d'un cas d'espèce donné. ...

"investment tax credit" " has the meaning assigned to that expression by subsection 127(9) of the Act. ... In XXXXXXXXXX, the Company received the final feasibility study that concluded that an underground mining project could increase the Company's annual XXXXXXXXXX production by XXXXXXXXXX %. ... The above ruling is given subject to the general limitations and qualifications set forth in Information Circular 70-6R5 issued by the Canada Customs and Revenue Agency (the "Agency") on May 17, 2002 and is binding on the Agency provided that the proposed exploration program described in paragraphs 8 through 11 above is completed by XXXXXXXXXX. ...

Early redemption ACO will have the right to redeem the Notes, in whole or in part, at a price equal to XXXXXXXXXX% of the principal amount of the Notes to be redeemed, plus accrued and unpaid interest to the date of redemption, by giving not less than XXXXXXXXXX and no more than XXXXXXXXXX days' prior notice on account of: • the termination of XXXXXXXXXX in respect of ACO's future obligations to pay the interest owing under the terms of the Initial Notes; • XXXXXXXXXX; any payment in respect of the Note becoming subject to additional amounts pursuant to a change of law, provided that no such notice of redemption shall be given earlier than XXXXXXXXXX days prior to the earliest date on which the ACO would be obliged to pay such additional amounts in relation to a payment in respect of Notes in accordance with the Indenture General redemption right The Notes shall be redeemable commencing XXXXXXXXXX and on each interest payment date thereafter, in whole or in part, at the option of ACO on not less than XXXXXXXXXX and not more than XXXXXXXXXX day's notice at a redemption price equal to XXXXXXXXXX% of the principal amount thereof, together in each case with accrued and unpaid interest to the date fixed for redemption. ... The above rulings are subject to the limitations and qualifications set out in Information Circular 70-6R5 dated May 17, 2002 and are binding on CRA provided that the Notes are issued by XXXXXXXXXX. ...

Provided that: (a) at the moment of the transfer described in paragraph 23 Amalco MFC is a mutual fund corporation within the meaning assigned by subsection 131(8) and the Fund is a mutual fund trust within the meaning assigned by subsection 132(6); (b) the property transferred at that moment has a fair market value of at least 90% of the fair market value of all property owned by Amalco MFC at that moment; and (c) Amalco and the Fund jointly elect by timely filing a prescribed form under paragraph (c) of the definition of “qualifying exchange” in subsection 132.2, the transfer described in paragraph 23 will constitute a “qualifying exchange” within the meaning of subsection 132.2(2), such that the rules in subsection 132.2(1) will apply to: • the transfer of the property from Amalco MFC to the Fund described in paragraph 23; • the purchase for cancellation by Amalco MFC of the Amalco MFC Class A shares and Amalco MFC Class B shares described in paragraphs 25 and 26; and • the transfer of the Fund Units from Amalco MFC to holders of the Amalco MFC Class A shares and the Amalco MFC Class B shares described in paragraphs 25 and 26. ... These rulings are given subject to the limitations and qualifications set forth in Information Circular 70-6R5 issued on May 17, 2002, and are binding on the Canada Revenue Agency provided that the Proposed Transactions are, completed before XXXXXXXXXX. ... Provided that: (a) at the moment of the transfer described in paragraph 23 Amalco MFC is a mutual fund corporation within the meaning assigned by subsection 131(8) and the Fund is a mutual fund trust within the meaning assigned by subsection 132(6); (b) the property transferred at that moment has a fair market value of at least 90% of the fair market value of all property owned by Amalco MFC at that moment; and (c) Amalco and the Fund jointly elect by timely filing a prescribed form under paragraph (c) of the definition of “qualifying exchange” in subsection 132.2, as that subsection is proposed to be amended by subsection 72(1) of the Proposed Amendments, the transfer described in paragraph 23 will constitute a “qualifying exchange” within the meaning of subsection 132.2(1), as that subsection is proposed to be amended by subsection 72(1) of the Proposed Amendments, such that the rules in subsections 132.2(3) and (4), as proposed to be amended by subsection 72(1) of the Proposed Amendments will apply to: •the transfer of the property from Amalco MFC to the Fund described in paragraph 23; • the purchase for cancellation by Amalco MFC of the Amalco MFC Class A Shares and Amalco MFC Class B Shares and the transfer of the Fund Units from Amalco MFC to holders of the Amalco MFC Class A Shares and the Amalco MFC Class B Shares as described in paragraphs 25 and 26; and • the transactions described in paragraph 27. ...

XXXXXXXXXX 2002-017981 XXXXXXXXXX, 2003 Dear XXXXXXXXXX: Re: Advance Income Tax Ruling XXXXXXXXXX This is in reply to your letter of XXXXXXXXXX, wherein you requested certain modifications to the advance income tax ruling issued to the above-noted taxpayers on XXXXXXXXXX, 2002 (our file number 2002-016458 and referred to as the "Previous Ruling"). ... Consequently, its four founding shareholders currently own the common shares of Lossco as follows: Shareholder # of common shares Country of Residence Profitco XXXXXXXXXX Canada Forco1 XXXXXXXXXX United States XXXXXXXXXX ("Forco2") XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX ("Forco3") XXXXXXXXXX XXXXXXXXXX Profitco's aggregate adjusted cost base and aggregate paid-up capital attributable to its XXXXXXXXXX common shares of Lossco is $XXXXXXXXXX. 5. ...