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Miscellaneous severed letter
7 January 2005 Income Tax Severed Letter 2004-0068231I7 - Refundable tax of a retirement compensation arrangement
7 January 2005 Income Tax Severed Letter 2004-0068231I7- Refundable tax of a retirement compensation arrangement Unedited CRA Tags 207.5(1), 207.5(2), 207.7(1), 207.7(2) SUMMARY: Refundable tax of a retirement compensation arrangement—ITA-207.5(1), 207.5(2), 207.7(1), 207.7(2)—Calculation of the refundable tax on, the Part XI.3 tax return for a retirement compensation allowance, for the year following a subsec. 207.5(2) election. ... January 7, 2005 Winnipeg Taxation Centre HEADQUARTERS Retirement Compensation Unit Income Tax Rulings Directorate Attention: Carole Bisson P. ... These changes are referred to on pages 3 and 10 of the Draft 2004 RCA Guide (), which is available on the Canada Revenue Agency website. ...
Miscellaneous severed letter
7 July 2005 Income Tax Severed Letter 2005-0124152R3 - Trust variation—redemption rights
7 July 2005 Income Tax Severed Letter 2005-0124152R3- Trust variation—redemption rights Unedited CRA Tags 108(2), 132(6), 204.4(2) SUMMARY: Trust variation—redemption rights—ITA-108(2), 132(6), 204.4(2)—Advance income tax ruling—Amendments to advance income tax rulingissued in 2005 and relating to the variation of redemption rights for a trust. ... REASONS: Previous rulings XXXXXXXXXX 2005-012415 XXXXXXXXXX, 2005 Dear XXXXXXXXXX: Re: XXXXXXXXXX Amendment to Advance Income Tax Ruling We are writing in response to our telephone conversation (XXXXXXXXXX) wherein you requested an amendment to the Advance Income Tax Ruling #2005-012415 [] dated XXXXXXXXXX, 2005 with respect to the above named taxpayers (the “Ruling”). ... Yours truly, XXXXXXXXXX Acting Manager for Director International & Trusts Division Income Tax Rulings Directorate Policy and Planning Branch ...
Miscellaneous severed letter
7 July 2005 Income Tax Severed Letter 2005-0163141R3 - Amendment to proposed transactions for 2005-013289
7 July 2005 Income Tax Severed Letter 2005-0163141R3- Amendment to proposed transactions for 2005-013289 Unedited CRA Tags 87(2.1) SUMMARY: Amendment to proposed transactions for 2005-013289—ITA-87(2.1)—Advance income tax ruling—Amendments to advance income tax rulingissued in 2005. ... PRINCIPAL ISSUES: whether revisions to proposed transactions would have any impact on rulings given POSITION: no REASONS: revisions are inconsequential XXXXXXXXXX 2005-016314 XXXXXXXXXX, 2005 Dear XXXXXXXXXX: Re: XXXXXXXXXX Advance Income Tax Ruling No. 2005-013289 [] This is in reply to your letter of XXXXXXXXXX wherein you advised of us certain amendments to the proposed transactions described in advance income tax ruling 2005-013289 [2005-0132891R3] (the “Ruling Letter”) that was issued on XXXXXXXXXX, 2005. ...
Miscellaneous severed letter
7 July 2005 Income Tax Severed Letter 2005-0113591R3 - Supplemental ruling to 2004-009908
7 July 2005 Income Tax Severed Letter 2005-0113591R3- Supplemental ruling to 2004-009908 Unedited CRA Tags 248(1)(k)(ii), 248(25.2) SUMMARY: Supplemental ruling to 2004-009908—ITA-248(1)(k)(ii), 248(25.2)—Advance income tax ruling—Amendments to advance income tax ruling 2004-009908 issued in 2004. ... XXXXXXXXXX 2005-011359 XXXXXXXXXX, 2005 Dear XXXXXXXXXX: Re: XXXXXXXXXX Advance Income Tax Ruling Request 2004-009908, dated XXXXXXXXXX, 2004 We are writing in response to your request dated XXXXXXXXXX (the “Request”) on behalf of the above taxpayer for a Supplemental Ruling to Advance Income Tax Ruling number 2004-009908 (the “Ruling”) issued to the above taxpayer on XXXXXXXXXX, 2004. ... Yours truly, XXXXXXXXXX Section Manager For Division Director International & Trusts Division Income Tax Rulings Directorate Policy and Planning Branch ...
Miscellaneous severed letter
7 July 2005 Income Tax Severed Letter 2005-0117901R3 - Income trust reorganization
The following document was issued prior to the September 19, 2005 announcement that the provision of advance income tax rulings on income trusts and other flow-through entities would be postponed while the Department of Finance consultations are underway and until the government announces what action it may take. ... REASONS: No phantom losses will arise as a result of the amendments to section 132.2 announced on July 18, 2005. ... XXXXXXXXXX 2005-011790 XXXXXXXXXX, 2005 Dear XXXXXXXXXX: Re: Advance Income Tax Ruling XXXXXXXXXX—Trust Account Number XXXXXXXXXX (XXXXXXXXXX Tax Services Office, XXXXXXXXXX Taxation Centre) XXXXXXXXXX. ...