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Conference summary

6 October 2017 APFF Financial Strategies and Instruments Roundtable Q. 1, 2017-0705221C6 F - Property transfers - common law partners in Québec -- summary under Subsection 146.3(14)

Lola, 2013 SCC 5), it nonetheless “is not impossible for the annuitant to determine to create rights under a written separation agreement between the annuitant and the annuitant’s common-law partner or former common-law partner relating to the division of property” and that “such an agreement could be concluded at the time of separation, whether or not a common-law union agreement providing for the rights of each in the event of the union's failure had been previously signed.” ...
Conference summary

6 October 2017 APFF Roundtable Q. 15, 2017-0709141C6 F - Designation pursuant to paragraph 111(4)(e) -- summary under Paragraph 111(4)(e)

In addition, according to the facts provided, the goodwill is not a depreciable property to which subsection 111(5.1) would apply …. ...
Conference summary

6 October 2017 APFF Financial Strategies and Instruments Roundtable Q. 2, 2017-0710681C6 F - Withdrawal of RRSP over-contributions after death -- summary under Subsection 146(8.8)

. The fact that premiums paid to the RRSP prior to the time of death could not be deducted has no impact on the amount to be included. ...
Technical Interpretation - External summary

1 May 2018 External T.I. 2017-0709101E5 F - Travaux en cours -- summary under Paragraph 10(4)(a)

In these circumstances, the FMV of such work in progress of the designated professional at the end of the taxation year would be nil [except where] it is possible, at the end of the year, to establish an amount that can reasonably be expected to be received after the end of the taxation year in respect of that work. ...
Conference summary

16 May 2018 IFA Roundtable Q. 4, 2018-0748171C6 - Penalties for Non-Residents -- summary under Subsection 220(3)

In responding “generally, yes,” CRA indicated that where a non-resident taxpayer carries on a business in Canada through a permanent establishment, a failure to meet statutory deadlines will carry the associated statutory penalties but that CRA will consider, on a case-by-case basis, requests under s. 223(3) and (3.1) for relief of the resulting interest and penalties. ...
Conference summary

16 May 2018 IFA Roundtable Q. 4, 2018-0748171C6 - Penalties for Non-Residents -- summary under Subsection 247(4)

Accordingly, its failure to meet statutory deadlines will carry the associated statutory penalties but CRA will consider, on a case-by-case basis, requests under s. 223(3) and (3.1) for relief of the resulting interest and penalties. ...
Ruling summary

2017 Ruling 2016-0646891R3 - Pipeline and subsequent Split-up butterfly -- summary under Distribution

DC then transferred its marketable securities to three transferee corporations (TCs) for the three beneficiaries in consideration for “butterfly shares” but with DC holding onto the notes that it received on the immediate redemption of the butterfly shares for a redacted period of time, after which DC was wound-up into the TCs, thereby resulting in deemed winding-up dividends and in the notes being extinguished on their being assigned to the TCs. ...
Ruling summary

2017 Ruling 2016-0646891R3 - Pipeline and subsequent Split-up butterfly -- summary under Paragraph 186(1)(b)

DC then transferred its marketable securities to three transferee corporations (TCs) for the three beneficiaries in consideration for “butterfly shares” but with DC holding onto the notes that it received on the immediate redemption of the butterfly shares for a redacted period of time. ...
Ministerial Correspondence summary

12 July 2018 Ministerial Correspondence 2018-0761301M4 - Method used to establish mileage rates -- summary under Paragraph 118.2(2)(h)

did=117&lang=eng#tc-tm_4_1 includes a link to the kilometric rates for each Canadian province and territory. ...

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