Search - 辐射监测仪 校准

Results 811 - 820 of 3389 for 辐射监测仪 校准
Technical Interpretation - External summary

6 May 2025 External T.I. 2024-1031071E5 - Subparagraph 149(5)(e)(ii) and vacant land -- summary under Subparagraph 149(5)(e)(ii)

. [S]ubparagraph 149(5)(e)(ii) is intended to only exclude taxable capital gains from property that is required and used exclusively to meet the objectives of the tax-exempt NPO. [T]he parcel of land was used as a golf range for a brief five-year period (1998–2002) of its 35-year ownership (1990 to 2024). [S]uch limited or historical use is insufficient to meet the threshold of being property used exclusively for and directly in the course of providing facilities to members. ...
Technical Interpretation - External summary

18 December 2017 External T.I. 2017-0714971E5 F - Application of subsection 55(2) -- summary under Subsection 55(2)

The result in the amended return for Holdco would be that there would be federal tax payable in respect of the application of subsection 55(2) of $193,333 ($1,000,000 * 50% * 38 2/3%, of which $153,333 could be recovered in the event of a possible dividend payment by Holdco of at least $399,999). ...
Technical Interpretation - Internal summary

20 January 2021 Internal T.I. 2019-0832211I7 - Cross-border Restricted Share Units -- summary under Subparagraph 115(1)(a)(i)

., $1,800 = $1,000 + $800). Neal Armstrong. Summary of 20 January 2021 Internal T.I. 2019-0832211I7 under s. 126(1). ...
Technical Interpretation - External summary

27 March 2003 External T.I. 2002-0180045 F - DEDUCTION DES INTERETS -- summary under Subsection 74.1(1)

CCRA noted that “it is the net loss or income determined under the Act that is attributed” pursuant to s. 74.1(1), so that “the interest expense paid by Ms. A will be taken into account in determining the loss or income to be attributed to her spouse pursuant to subsection 74.1(1)” but that s. 245(1) might be determined to apply. ...
Technical Interpretation - Internal summary

30 May 2019 Internal T.I. 2019-0806761I7 - Late filing of 88(1)(d) designation -- summary under Paragraph 88(1)(d)

After quoting from Nassau Walnut to the effect that where the Minister changes the provision under which the taxpayer’s income is computed and the taxpayer then seeks a deduction under the new provision, that request does not raise the spectre of retroactive tax planning,” the Directorate then stated that here: [I]f the CRA has the ability to reassess the Taxpayer’s Part I income tax return for year-end #1 pursuant to subparagraph 152(4)(b)(iii) with respect to its disposition of the US shares the Taxpayer’s late-filed designation request could be considered. ...
Ruling summary

2016 Ruling 2014-0552321R3 F - Trust to trust Transfer -- summary under Paragraph (f)

The New Trust will not file an election under s. 248(1) disposition para. (f) subpara. (v) for that para. not to apply. Subsequent transactions Prior to the Winding-up Date, the Initial Trustee will exercise his discretionary power pursuant to the Deed of Trust for the New Trust for making an advance determination of the portions of the trust capital and income which will be distributed among Mr. ...
Conference summary

11 October 2019 APFF Financial Strategies and Instruments Roundtable Q. 6, 2019-0813451C6 F - TFSA - Bequest and disclaimer -- summary under Paragraph (b)

CRA stated that “the principal question is whether the payment is made as a consequence of the individual's death” and, in addition to referencing the s. 248(8)(b) rule, noted that “paragraph 248(8)(a) provides, in particular, that a transfer of property made as a consequence of [the taxpayer’s] will is considered to be a transfer made as a consequence of the death of the taxpayer.” ...
Technical Interpretation - Internal summary

5 December 2012 Internal T.I. 2012-0439301I7 F - Reassessment beyond the normal reassessment period -- summary under Subparagraph 152(4)(b)(iii)

…Paragraph 96(1)(a)[‘s] presumption that a partnership is a separate person does not apply for the purposes of section 152.... Furthermore …., under civil and common law, a partnership is simply the relationship that exists between persons or partners who carry on a business in common for profit. ... The debt of the partnership is owed by the partners …. ...
Technical Interpretation - External summary

17 February 2021 External T.I. 2018-0768051E5 F - Contrat de crédit-bail -- summary under Section 68

Aco will be able to deduct the portion of the periodic amounts of the consideration relating to the use of the property …. By contrast, the portion of the periodic amounts of the consideration relating to the acquisition of a purchase option on the Vehicle should be considered as expenditures of a capital nature for the acquisition of a capital property. To the extent that Aco exercises its purchase option Aco's cost of the Vehicle pursuant to subsection 49(3) will be the sum paid in accordance with the exercise price plus the adjusted cost base of the option, which will be the portion of the consideration paid that is attributable to the acquisition of that option. ...
Technical Interpretation - External summary

31 May 2000 External T.I. 2000-0009695 F - FRAIS MEDICAUX-PREPOSE A PLEIN TEMPS -- summary under Paragraph 118.2(2)(b)

31 May 2000 External T.I. 2000-0009695 F- FRAIS MEDICAUX-PREPOSE A PLEIN TEMPS-- summary under Paragraph 118.2(2)(b) Summary Under Tax Topics- Income Tax Act- Section 118.2- Subsection 118.2(2)- Paragraph 118.2(2)(b) meaning of “one full-time attendant for the full-time care of the individual” An individual received home care for 24 hours a day from an attendant for tasks such as getting up, washing, and preparing meals. ... In the course of a general discussion regarding whether the test of "one full-time attendant for the full-time care of the individual" was satisfied, the Agency stated: [T]he expression "one full-time attendant" is not intended to mean one attendant only looking after the patient on a continuous basis but rather several attendants could be utilized over a specific period of time so long as there is only one attendant for any given period of time. [T]he expression “one full-time attendant for the full-time care of the individual” does not impose a minimum period of time during which care must be provided by a particular attendant. ...

Pages