Search - 辐射监测仪 校准

The Taxpayer is a taxable Canadian-controlled private corporation, XXXXXXXXX % of the shares of which are owned by an individual, XXXXXXXXX. ...

Upon the amalgamation of XXXXXXXXXX, as described in paragraph 13 above: (i) by virtue of subsection 87(1.1), the provisions of subsection 87(1) will apply; (ii) the provisions of paragraph 87(2)(a) will apply such that New XXXXXXXXXX will be deemed to be a new corporation the first taxation year of which will commence at the time of the amalgamation and XXXXXXXXXX will be deemed to have a taxation year end immediately before the amalgamation; (iii) the provisions of paragraph 87(2)(d) will apply in determining the capital cost and UCC to New XXXXXXXXXX of depreciable property; (iv) by virtue of paragraph 1102(14)(d) of the Regulations, depreciable property of a prescribed class of a predecessor corporation that is acquired by New XXXXXXXXXX upon the amalgamation will be deemed to be property of the same prescribed class to New XXXXXXXXXX; (v) in respect of each depreciable property acquired by New XXXXXXXXXX in respect of which the conditions described in Regulation 1100(2.2)(g) are met, the following rules will apply: (a) no amount will be included under Regulation 1100(2)(a) in respect of the property; and (b) each Class 24, Class 27, Class 29 and Class 34 asset will be deemed to be a "designated property " of the respective prescribed class to New XXXXXXXXXX for the purposes of Regulation 1100(1)(ta); and (vi) New XXXXXXXXXX will be entitled to deduct, pursuant to paragraph 20(1)(a), such CCA as is allowed by the Regulations, in computing income for its first taxation year. ...

To the best of your knowledge, and that of the taxpayers involved, none of the issues contained herein is: (i) dealt with in an earlier return of the taxpayers or a related person; (ii) being considered by a tax services office or taxation centre in connection with a previously filed tax return of the taxpayers or a related person; (iii) under objection by the taxpayers or a related person; (iv) subject to a ruling previously issued by the Income Tax Rulings & Interpretations Directorate; or (v) before the courts or, if a judgement has been issued, the time limit for appeal to a higher court has not expired. ...

To the best of your knowledge, and that of the taxpayers involved, other than specifically disclosed in your letter of XXXXXXXXXX, none of the issues contained herein is: (i) dealt with in an earlier return of the taxpayers or a related person; (ii) being considered by a tax services office or taxation centre in connection with a previously filed tax return of the taxpayers or a related person; (iii) under objection by the taxpayers or a related person; (iv) subject to a ruling previously issued by the Income Tax Rulings & Interpretations Directorate; or (v) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has not expired. ...

" As stated in this excerpt, the profit and loss experience is a factor in assessing whether a reasonable expectation of profit is present. ...

The term "Indian", as used in the Guidelines, is defined on page 10 of the Guidelines to mean "an Indian as defined for purposes of the Indian Act ". ...

The terms and conditions of the BCO Loan are as follows: a) The BCO Loan will be repayable in cash or in kind upon demand. b) Interest, at the Applicable Rate, will accrue daily on the outstanding principal amount and be payable periodically on each Payment Date. c) "Payment Date" is defined as XXXXXXXXXX. d) "Quarter " is defined as any 3 consecutive months ending on a Payment Date. e) The "Applicable Rate" of interest for any Quarter is equal to the Applicable Rate of Interest on the Loan plus 10 basis points. f) The first payment date will be XXXXXXXXXX. 8. ...

Brian Arnold's article "Canada Amends Income Tax Convention Interpretation Act " published in Tax Notes International, vol. 18, Number 6, February 8, 1999. ...

" The Supreme Court of Canada found in Savage, 83 DTC 5409 and Nowegijick, 83 DTC 5041 that the words "in respect of" are "... of the widest possible scope. ...

A "qualifying amount" received by an individual in a taxation year means, inter alia, "...an amount (other than the portion of the amount that can reasonably be considered to be received as, on account of, in lieu of payment of or in satisfaction of, interest) that is included in computing the individual's income for the year and is (a) an amount (i) that is received pursuant to an order or judgment of a competent tribunal, an arbitration award or a contract by which the payor and the individual terminate a legal proceeding, and (ii) that is (A) included in computing the individual's income from an office or employment, or (B) received as, on account of, in lieu of payment of or in satisfaction of, damages in respect of the individual's loss of an office or employment, [...]." ...