Search - 跨文化交际案例与分析 朱勇 pdf
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Archived CRA website
ARCHIVED - Distress Preferred Shares
Notice-- Bulletins do not have the force of law This document is also available for download in PDF format. ... Distress Preferred Shares Contents Application Summary Discussion and Interpretation GENERAL Introduction (¶s 1-2) Income Bonds and Income Debentures (¶ 3) Cost Considerations (¶ 4) Advance Income Tax Ruling (¶ 5) LEGISLATION Definition (¶ 6) Term (¶s 7-8) Companies Creditors' Arrangement Act (¶ 9) Determining Financial Difficulty (¶s 10-11) Use of Daylight Loans (¶ 12) Replacement of Debt (¶ 13) Use of Proceeds (¶s 14-17) STRUCTURE Description (¶s 18-19) Restrictions that apply to Newco (¶s 20-21) REQUESTING AN ADVANCE INCOME TAX RULING General (¶s 22-23) Excess Cash Flow (¶s 24-25) Rulings Procedures (¶s 26-27) Appendix I. ... Companies Creditors' Arrangement Act ¶ 9. The circumstances described in ¶ 6 (a)(i) and (ii) above are specific and are generally not difficult to confirm. ...
Archived CRA website
ARCHIVED - Distress Preferred Shares
Notice-- Bulletins do not have the force of law This document is also available for download in PDF format. ... Distress Preferred Shares Contents Application Summary Discussion and Interpretation GENERAL Introduction (¶s 1-2) Income Bonds and Income Debentures (¶ 3) Cost Considerations (¶ 4) Advance Income Tax Ruling (¶ 5) LEGISLATION Definition (¶ 6) Term (¶s 7-8) Companies Creditors' Arrangement Act (¶ 9) Determining Financial Difficulty (¶s 10-11) Use of Daylight Loans (¶ 12) Replacement of Debt (¶ 13) Use of Proceeds (¶s 14-17) STRUCTURE Description (¶s 18-19) Restrictions that apply to Newco (¶s 20-21) REQUESTING AN ADVANCE INCOME TAX RULING General (¶s 22-23) Excess Cash Flow (¶s 24-25) Rulings Procedures (¶s 26-27) Appendix I. ... Companies Creditors' Arrangement Act ¶ 9. The circumstances described in ¶ 6 (a)(i) and (ii) above are specific and are generally not difficult to confirm. ...
Archived CRA website
ARCHIVED - Consolidated, Clergy Residence Deduction
What the "Archived Content" notice means for interpretation bulletins NO: IT-141R (Consolidated) DATE: See Bulletin Revisions section SUBJECT: INCOME TAX ACT Clergy Residence Deduction REFERENCE: Paragraph 8(1)(c) (also subsection 8(10)) Notice-- Bulletins do not have the force of law This document is also available for download in PDF format. ... Member of the Clergy or Regular Minister ¶ 3. Whether a person is a "member of the clergy" or a "regular minister" depends upon the structure and practices of the particular church or religious denomination. ¶ 4. ... No factor predominates and each must be assigned its proper weight in the context of all the facts. ¶ 9. ...
Archived CRA website
ARCHIVED - Clergy Residence Deduction
What the "Archived Content" notice means for interpretation bulletins NO: IT-141R (Consolidated) DATE: See Bulletin Revisions section SUBJECT: INCOME TAX ACT Clergy Residence Deduction REFERENCE: Paragraph 8(1)(c) (also subsection 8(10)) Notice-- Bulletins do not have the force of law This document is also available for download in PDF format. ... Member of the Clergy or Regular Minister ¶ 3. Whether a person is a "member of the clergy" or a "regular minister" depends upon the structure and practices of the particular church or religious denomination. ¶ 4. ... No factor predominates and each must be assigned its proper weight in the context of all the facts. ¶ 9. ...
Archived CRA website
ARCHIVED - Clergy Residence Deduction
What the "Archived Content" notice means for interpretation bulletins NO: IT-141R (Consolidated) DATE: See Bulletin Revisions section SUBJECT: INCOME TAX ACT Clergy Residence Deduction REFERENCE: Paragraph 8(1)(c) (also subsection 8(10)) Notice-- Bulletins do not have the force of law This document is also available for download in PDF format. ... Member of the Clergy or Regular Minister ¶ 3. Whether a person is a "member of the clergy" or a "regular minister" depends upon the structure and practices of the particular church or religious denomination. ¶ 4. ... No factor predominates and each must be assigned its proper weight in the context of all the facts. ¶ 9. ...
Archived CRA website
ARCHIVED - Visual Artists and Writers
.: IT-504R2 (Consolidated) DATE: See Bulletin Revisions section SUBJECT: INCOME TAX ACT Visual Artists and Writers REFERENCE: Section 9 (also sections 67.1, 110.4, and 110.6, subsections 10(1), (6), (7), and (8), 18(12), 70(5), and 118.1(1), (6), (7), (7.1), and (10); paragraphs 8(1)(j), 8(1)(q), and 69(1)(b) of the Income Tax Act and Parts XVIII and XXXV of the Income Tax Regulations) Notice-- Bulletins do not have the force of law This document is also available for download in PDF format. ... The following information relates to the artist for that taxation year: Employer A Employer B Total Income received in the year $ 15,000 $ 7,500 $ 22,500 ===== ===== ===== Related expenses paid in the year: Advertising & promotion $ 400 $ 300 $ 700 Travel* $ 800 $ 500 $ 1,300------------------------ Total $ 1,200 $ 800 $ 2,000 ===== ===== ===== Capital cost allowance on motor vehicle deducted under paragraph 8(1)(j) $ 350 ===== * The taxpayer meets the requirements of paragraph 8(1)(h); consequently, the travel expenses are deductible under that provision. The amount deductible under paragraph 8(1)(q) for the current year is calculated as follows: Eligible artists' employment expenses (amount paid for advertising & promotion-see note below) $ 700 ===== Limit under paragraph 8(1)(q): The lesser of: (i) $1,000, and (ii) $4,500 (20% of $22,500); that is, $ 1,000 Less: capital cost allowance $ 350 $ 650-------- ===== Amount deductible under paragraph 8(1)(q) for the year (the eligible expenses of $700, but not exceeding the limit of $650) $ 650 ===== Eligible artists' employment expenses to be carried onward to the subsequent year ($700 eligible- $650 deductible) $ 50 ===== Deductions allowed in computing the current year's employment income: Capital cost allowance (paragraph 8(1)(j)) $ 350 Artists' employment expenses (paragraph 8(1)(q)) $ 650 Travel expenses (paragraph 8(1)(h)) $ 1,300-------- Total $ 2,300 ===== Note: Since the travel expenses of $1,300 were paid to earn employment income from a qualifying artistic activity, the taxpayer could choose to include them in the eligible artists' employment expenses instead of deducting them under paragraph 8(1)(h) (the eligible artists' employment expenses would therefore be $2,000 instead of $700). ...
Archived CRA website
ARCHIVED - Visual Artists and Writers
.: IT-504R2 (Consolidated) DATE: See Bulletin Revisions section SUBJECT: INCOME TAX ACT Visual Artists and Writers REFERENCE: Section 9 (also sections 67.1, 110.4, and 110.6, subsections 10(1), (6), (7), and (8), 18(12), 70(5), and 118.1(1), (6), (7), (7.1), and (10); paragraphs 8(1)(j), 8(1)(q), and 69(1)(b) of the Income Tax Act and Parts XVIII and XXXV of the Income Tax Regulations) Notice-- Bulletins do not have the force of law This document is also available for download in PDF format. ... The following information relates to the artist for that taxation year: Employer A Employer B Total Income received in the year $ 15,000 $ 7,500 $ 22,500 ===== ===== ===== Related expenses paid in the year: Advertising & promotion $ 400 $ 300 $ 700 Travel* $ 800 $ 500 $ 1,300------------------------ Total $ 1,200 $ 800 $ 2,000 ===== ===== ===== Capital cost allowance on motor vehicle deducted under paragraph 8(1)(j) $ 350 ===== * The taxpayer meets the requirements of paragraph 8(1)(h); consequently, the travel expenses are deductible under that provision. The amount deductible under paragraph 8(1)(q) for the current year is calculated as follows: Eligible artists' employment expenses (amount paid for advertising & promotion-see note below) $ 700 ===== Limit under paragraph 8(1)(q): The lesser of: (i) $1,000, and (ii) $4,500 (20% of $22,500); that is, $ 1,000 Less: capital cost allowance $ 350 $ 650-------- ===== Amount deductible under paragraph 8(1)(q) for the year (the eligible expenses of $700, but not exceeding the limit of $650) $ 650 ===== Eligible artists' employment expenses to be carried onward to the subsequent year ($700 eligible- $650 deductible) $ 50 ===== Deductions allowed in computing the current year's employment income: Capital cost allowance (paragraph 8(1)(j)) $ 350 Artists' employment expenses (paragraph 8(1)(q)) $ 650 Travel expenses (paragraph 8(1)(h)) $ 1,300-------- Total $ 2,300 ===== Note: Since the travel expenses of $1,300 were paid to earn employment income from a qualifying artistic activity, the taxpayer could choose to include them in the eligible artists' employment expenses instead of deducting them under paragraph 8(1)(h) (the eligible artists' employment expenses would therefore be $2,000 instead of $700). ...
Archived CRA website
ARCHIVED - Visual Artists and Writers
.: IT-504R2 (Consolidated) DATE: See Bulletin Revisions section SUBJECT: INCOME TAX ACT Visual Artists and Writers REFERENCE: Section 9 (also sections 67.1, 110.4, and 110.6, subsections 10(1), (6), (7), and (8), 18(12), 70(5), and 118.1(1), (6), (7), (7.1), and (10); paragraphs 8(1)(j), 8(1)(q), and 69(1)(b) of the Income Tax Act and Parts XVIII and XXXV of the Income Tax Regulations) Notice-- Bulletins do not have the force of law This document is also available for download in PDF format. ... The following information relates to the artist for that taxation year: Employer A Employer B Total Income received in the year $ 15,000 $ 7,500 $ 22,500 ===== ===== ===== Related expenses paid in the year: Advertising & promotion $ 400 $ 300 $ 700 Travel* $ 800 $ 500 $ 1,300------------------------ Total $ 1,200 $ 800 $ 2,000 ===== ===== ===== Capital cost allowance on motor vehicle deducted under paragraph 8(1)(j) $ 350 ===== * The taxpayer meets the requirements of paragraph 8(1)(h); consequently, the travel expenses are deductible under that provision. The amount deductible under paragraph 8(1)(q) for the current year is calculated as follows: Eligible artists' employment expenses (amount paid for advertising & promotion-see note below) $ 700 ===== Limit under paragraph 8(1)(q): The lesser of: (i) $1,000, and (ii) $4,500 (20% of $22,500); that is, $ 1,000 Less: capital cost allowance $ 350 $ 650-------- ===== Amount deductible under paragraph 8(1)(q) for the year (the eligible expenses of $700, but not exceeding the limit of $650) $ 650 ===== Eligible artists' employment expenses to be carried onward to the subsequent year ($700 eligible- $650 deductible) $ 50 ===== Deductions allowed in computing the current year's employment income: Capital cost allowance (paragraph 8(1)(j)) $ 350 Artists' employment expenses (paragraph 8(1)(q)) $ 650 Travel expenses (paragraph 8(1)(h)) $ 1,300-------- Total $ 2,300 ===== Note: Since the travel expenses of $1,300 were paid to earn employment income from a qualifying artistic activity, the taxpayer could choose to include them in the eligible artists' employment expenses instead of deducting them under paragraph 8(1)(h) (the eligible artists' employment expenses would therefore be $2,000 instead of $700). ...
Archived CRA website
ARCHIVED - Capital Cost Allowance -- Patents, Franchises, Concessions and Licences
"Life of the Property" and "Limited Period" ¶ 14. ... If so, the additional periods are included in the life of the property. ¶ 16. ... [November 27, 2001] The example given in ¶ 5 was updated so as not to contradict the revised interpretative position set out in ¶ 4. ...
Archived CRA website
ARCHIVED - Capital Cost Allowance -- Patents, Franchises, Concessions and Licences
"Life of the Property" and "Limited Period" ¶ 14. ... If so, the additional periods are included in the life of the property. ¶ 16. ... [November 27, 2001] The example given in ¶ 5 was updated so as not to contradict the revised interpretative position set out in ¶ 4. ...