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Archived CRA website

ARCHIVED - Shares Sold Subject to an Earnout Agreement

It is also available in other formats, including PDF (which is an exact rendition of the printed publication). ... It is the CRA's position that a reasonable reserve under such circumstances is equal to the lesser of: (a) (A ÷ B) × C A = the aggregate of determined capital gains at the end of the taxation year B = the aggregate of determinable amounts at the end of the taxation year C = the aggregate of amounts payable after the end of the taxation year and (b) (A ÷ B) × C A = the amount, if any, by which 4 exceeds the number of preceding taxation years ending after the disposition of the property B = 5 C = aggregate of determined capital gains at the end of the taxation year A “determined capital gain” in the formula above means a capital gain (before the reserve) calculated pursuant to the rules in ¶s 3 to 5 under the cost recovery method. ... New 2 was previously included in former 1. In new 2, the fourth condition has been modified in order to clarify the meaning of the 5-year period. ...
Archived CRA website

ARCHIVED - Shares Sold Subject to an Earnout Agreement

It is also available in other formats, including PDF (which is an exact rendition of the printed publication). ... It is the CRA's position that a reasonable reserve under such circumstances is equal to the lesser of: (a) (A ÷ B) × C A = the aggregate of determined capital gains at the end of the taxation year B = the aggregate of determinable amounts at the end of the taxation year C = the aggregate of amounts payable after the end of the taxation year and (b) (A ÷ B) × C A = the amount, if any, by which 4 exceeds the number of preceding taxation years ending after the disposition of the property B = 5 C = aggregate of determined capital gains at the end of the taxation year A “determined capital gain” in the formula above means a capital gain (before the reserve) calculated pursuant to the rules in ¶s 3 to 5 under the cost recovery method. ... New 2 was previously included in former 1. In new 2, the fourth condition has been modified in order to clarify the meaning of the 5-year period. ...
Archived CRA website

ARCHIVED - Permanent Establishment of a Corporation in a Province

It is also available in other formats, including PDF (which is an exact rendition of the printed publication). ... Contents Application Summary Discussion and Interpretation Definition 1) Determination 2) Fixed Place of Business 3) Employee or Agent (¶s 4-5) Substantial Usage of Machinery or Equipment 6) Rental Operation 7) Subsidiary of a Corporation 8) Bulletin Revisions Application This bulletin is a consolidation of the following: Interpretation Bulletin IT-177R2 dated May 4, 1984; Special Release to IT-177R2 dated August 25, 1995; and subsequent amendments thereto. For further particulars, see the " Bulletin Revision " section near the end of this bulletin. ...
Archived CRA website

ARCHIVED - Permanent Establishment of a Corporation in a Province

It is also available in other formats, including PDF (which is an exact rendition of the printed publication). ... Contents Application Summary Discussion and Interpretation Definition 1) Determination 2) Fixed Place of Business 3) Employee or Agent (¶s 4-5) Substantial Usage of Machinery or Equipment 6) Rental Operation 7) Subsidiary of a Corporation 8) Bulletin Revisions Application This bulletin is a consolidation of the following: Interpretation Bulletin IT-177R2 dated May 4, 1984; Special Release to IT-177R2 dated August 25, 1995; and subsequent amendments thereto. For further particulars, see the " Bulletin Revision " section near the end of this bulletin. ...
Archived CRA website

ARCHIVED - Permanent Establishment of a Corporation in a Province

It is also available in other formats, including PDF (which is an exact rendition of the printed publication). ... Contents Application Summary Discussion and Interpretation Definition 1) Determination 2) Fixed Place of Business 3) Employee or Agent (¶s 4-5) Substantial Usage of Machinery or Equipment 6) Rental Operation 7) Subsidiary of a Corporation 8) Bulletin Revisions Application This bulletin is a consolidation of the following: Interpretation Bulletin IT-177R2 dated May 4, 1984; Special Release to IT-177R2 dated August 25, 1995; and subsequent amendments thereto. For further particulars, see the " Bulletin Revision " section near the end of this bulletin. ...
Archived CRA website

ARCHIVED - Timber Resource Property and Timber Limits

It is also available in other formats, including PDF (which is an exact rendition of the printed publication). ... For further particulars, see the Bulletin Revisions section near the end of this bulletin. ... [January 13, 2004] In 7, the first and part of the second sentence of former 8 have been deleted in order to eliminate superfluous wording. ...
Archived CRA website

ARCHIVED - Timber Resource Property and Timber Limits

It is also available in other formats, including PDF (which is an exact rendition of the printed publication). ... For further particulars, see the Bulletin Revisions section near the end of this bulletin. ... [January 13, 2004] In 7, the first and part of the second sentence of former 8 have been deleted in order to eliminate superfluous wording. ...
Archived CRA website

ARCHIVED - Timber Resource Property and Timber Limits

It is also available in other formats, including PDF (which is an exact rendition of the printed publication). ... For further particulars, see the Bulletin Revisions section near the end of this bulletin. ... [January 13, 2004] In 7, the first and part of the second sentence of former 8 have been deleted in order to eliminate superfluous wording. ...
Archived CRA website

ARCHIVED - Pipelines

It is also available in other formats, including PDF (which is an exact rendition of the printed publication). ... However, other pipelines acquired for the purpose of gaining or producing income from a mine will be included in Class 1(l) (subject to the comments in 8). 8. ... An Index, Application Section (part of former 1) and Summary Section (part of former 1) have been added to the bulletin. ...
Archived CRA website

ARCHIVED - Pipelines

It is also available in other formats, including PDF (which is an exact rendition of the printed publication). ... However, other pipelines acquired for the purpose of gaining or producing income from a mine will be included in Class 1(l) (subject to the comments in 8). 8. ... An Index, Application Section (part of former 1) and Summary Section (part of former 1) have been added to the bulletin. ...

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