Search - 辐射监测仪 校准
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Technical Interpretation - External summary
14 October 2004 External T.I. 2004-0089921E5 F - Disposition d'une police d'assurance-vie -- summary under Element L
. … [O]ne item that generally reduces the adjusted cost basis [of the policy] is the "net cost of pure insurance", as defined in subsection 308(1) of the Income Tax Regulations, calculated immediately before the end of the calendar year ending in a taxation year commencing after May 31, 1985, in respect of an interest in a life insurance policy (other than an annuity contract) last acquired after December 1, 1982. ...
Technical Interpretation - External summary
16 November 2004 External T.I. 2004-0064821E5 F - 88(1) Bump -- summary under Subparagraph 88(1)(c.3)(ii)
. … [S]ubparagraph 88(1)(c.3)(ii) would not apply in such a situation. ...
Technical Interpretation - External summary
16 November 2004 External T.I. 2004-0064821E5 F - 88(1) Bump -- summary under Subclause 88(1)(c)(vi)(B)(I)
. … [S]ubparagraph 88(1)(c.3)(ii) would not apply in such a situation. ...
Technical Interpretation - External summary
8 November 2004 External T.I. 2004-0092021E5 F - RDTOH: Foreign tax credit under sub. 126(1) -- summary under Variable B
. … [A]ny amount so deducted by the Corporation would reduce the Foreign Tax Credit under subsection 126(1) and thus no longer affect the calculation of its RDTOH. ...
Technical Interpretation - External summary
30 November 2004 External T.I. 2004-0090181E5 F - Assurance maladie grave -- summary under Income-Producing Purpose
. … Premiums paid by the corporation for the rider to the policy allowing it to obtain a premium refund amount if the shareholder does not have one of the covered illnesses or medical conditions after 10 years are not deductible on the basis of the application of paragraphs 18(1)(a) and 18(1)(h). ...
Technical Interpretation - External summary
17 November 2004 External T.I. 2004-0097131E5 F - Travail temporaire; négociation de contrats -- summary under Subparagraph 6(1)(b)(v)
For example … negotiating a collective agreement would not include the duties of ensuring its application and representing the union's employee members in a grievance. ...
Technical Interpretation - Internal summary
3 November 2004 Internal T.I. 2004-0083791I7 F - Paragraphe 44.1(2) -- summary under Eligible Small Business Corporation
Before concluding that “the new corporation did not carry on a business at the time the shares were issued” so that “those shares were not shares of an eligible small business corporation,” CRA noted that there was no evidence that “a software development activity … [had] started at the time the taxpayer invested in the corporation,” and also stated: [T]here may be arguments that the business was started at the time that steps to change the zoning were taken. ...
Technical Interpretation - External summary
9 December 2004 External T.I. 2004-0093621E5 F - REÉR et faillite -- summary under Subsection 146(8)
Beaudoin … 2004 DTC 2414, held that the payment of funds from an RRSP to pay a debt extinguished by the order of discharge of a bankrupt does not constitute the receipt of a benefit by the bankrupt within the meaning of subsection 146(8), since the bankrupt does not receive any money or benefit as a result of that payment. ...
Technical Interpretation - Internal summary
10 December 2004 Internal T.I. 2004-0082341I7 F - Dissolution d'un syndicat -- summary under Paragraph 6(1)(j)
In indicating that a portion of the sums distributed appeared to be taxable under s. 6(1)(j), with the balance being proceeds of disposition of memberships (having a nominal adjusted cost base), the Directorate stated: [T]here are good arguments to state that the amount received … by each of the members, up to the amount of their union dues paid in XXXXXXXXXX, constitutes a refund of their annual dues that reduces or cancels the deduction provided for in subparagraph 8(1)(i)(iv) in computing their employment income. ...
Technical Interpretation - Internal summary
16 December 2004 Internal T.I. 2004-0098631I7 F - Déduction - Résidence des membres du clergé -- summary under Paragraph 8(1)(c)
. … [We cannot] conclude that they are regular ministers because they are not authorized to perform most or all of the functions of a minister, including administering most of the sacraments of the Roman Catholic Church. ...