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Conference summary
7 October 2011 Roundtable, 2011-0413081C6 F - 227(4) et (4.1) - vente d'un bien à un tiers -- summary under Subsection 227(4.1)
In that regard … the scope of the deemed trust cannot be limited by the fact that a secured creditor could in certain circumstances be equated with a third party purchaser. ...
Technical Interpretation - Internal summary
14 May 2005 Internal T.I. 2008-0304841I7 - Interest deductibility -- summary under Paragraph 20(1)(c)
. … CanOpco's legal obligation to pay interest expired on the day it obtained protection from its creditors under the CCAA. ...
Conference summary
10 October 2014 APFF Roundtable, 2014-0534821C6 F - Question 2 - APFF Round Table -- summary under Paragraph 212(1)(l)
. … [T]he CRA does not intend to provide any administrative relief to the non-resident surviving spouse who does not hold or cannot obtain a SIN so as to effect a tax-free transfer to an RRSP or a RRIF, as described above. ...
Ruling summary
2013 Ruling 2012-0458091R3 - XXXXXXXXXX - loss consolidation -- summary under Paragraph 111(1)(a)
Parent makes a daylight loan to a partnership (New LP) formed by the Profitcos (Parent and two wholly-owned subsidiaries – Aco and CCo, with another wholly-owned subsidiary, BCo as the GP). ...
Technical Interpretation - External summary
15 November 2012 External T.I. 2012-0456201E5 F - Frais médicaux - calcul et dépenses non admissibles -- summary under Subsection 118.2(1)
. … [T]o be eligible as medical expenses for the purposes of the METC, the expenses must be incurred, paid for, and evidenced by a receipt within the same 12-month period ending in a taxation year. ...
Technical Interpretation - Internal summary
15 September 2015 Internal T.I. 2015-0572771I7 - T1135 - Normal Reassessment Period -- summary under Subsection 152(4)
. … The failure to file the Form T1135 return on time results in the assessment of penalties under subsection 162(7), which is in Part I of the Act. ...
Technical Interpretation - External summary
15 August 2014 External T.I. 2014-0532941E5 - T5 reporting obligations -- summary under Subsection 201(1)
. … T5 slips will also have to be issued when interest is paid by the Brokers to their Clients. ...
Conference summary
10 October 2014 APFF Roundtable Q. 26, 2014-0538201C6 F - 2014 APFF Roundtable, Q. 26 - Cost of property -- summary under Shares
. … As for FMV, it generally represents the highest price obtainable for a property on a sale in a free and open market between two willing, informed and prudent persons acting independently. ...
Conference summary
10 October 2014 APFF Roundtable Q. 26, 2014-0538201C6 F - 2014 APFF Roundtable, Q. 26 - Cost of property -- summary under Subsection 247(2)
. … As for FMV, it generally represents the highest price obtainable for a property on a sale in a free and open market between two willing, informed and prudent persons acting independently. ...
Technical Interpretation - Internal summary
24 December 2013 Internal T.I. 2013-0512551I7 - Thin Cap and partnership income -- summary under Subsection 18(4)
The correspondent considered that the retained earnings of ULC should exclude its proportionate share of the Partnership income for the stub period on the basis that " 2007-0248961R3 indicate[s]... that section 96 informs the determination of the amount of partnership income to be included in determining the amount of a corporate partner's retained earnings for the purpose of the thin capitalization rules. ...