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Technical Interpretation - Internal

16 April 2012 Internal T.I. 2011-0404271I7 - Restitution of property looted during WWII

The Queen, 2009 TCC 293 as follows: Cranswick must be read in light of the fact that the trial judge's statement that the payment was not made by reason of any enforceable claim asserted by the shareholders of the Canadian subsidiary results from a specific statement to that effect contained in an agreed statement of facts. ...
Technical Interpretation - External

23 June 2016 External T.I. 2016-0627571E5 - Application of proposed amendments to section 55

The terms “reasonable dividend income return on a […] listed share” refer to dividends paid regularly by widely-held corporations to their shareholders on publicly listed shares. ...
Ruling

2011 Ruling 2011-0396421R3 - Permanent Establishment

(d) "XXXXXXXXXX " is described in Paragraph 2. (e) "CRA" means the Canada Revenue Agency. ...
Technical Interpretation - Internal

28 July 2011 Internal T.I. 2011-0394981I7 - Cooperative Housing and 149(1)(l)

C.35: Subsection 55(1) "... [T]he surplus arising from the business of a co-operative... in each fiscal year shall be allocated, credited or paid to the members in proportion to the business done by each member with or through the co-operative... ...
Technical Interpretation - External

3 October 2011 External T.I. 2011-0396601E5 - education tax credit and textbook tax credit

The Resident Program in our opinion seems to be more of a training program provided by the Resident's employer, the various hospitals in XXXXXXXXXX, where according to the information provided, the training and instruction seems to be provided, and designed so the doctors can prepare for examinations given by the Medical Council of Canada so they can be licensed by the College of Physicians & Surgeons of XXXXXXXXXX to practice medicine rather than, a qualifying educational program where a student is engaged in academic course study at a designated educational institution. ...
Ruling

2010 Ruling 2010-0383661R3 - Carrying on Business in Canada

Yours truly, for Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...
Technical Interpretation - Internal

13 April 2010 Internal T.I. 2010-0358541I7 - Annual gains limit

As explained by Ottawa TSO's Appeals Division, the Rep's position after reviewing the calculation in the TSO's schedule is as follows: "XXXXXXXXXX " Our Comments In our view, the amount of net capital losses deducted under paragraph 111(1)(b) in XXXXXXXXXX that is to be taken into account in computing the amount referred to in subparagraph (a)(i) of parameter B in the definition of the AGL in subsection 110.6(1), which amount in turn affects the amount determined for paragraph (b) of the definition of CGL, should be $XXXXXXXXXX (i.e., $XXXXXXXXXX less $XXXXXXXXXX). ...
Technical Interpretation - External

15 July 2010 External T.I. 2010-0361991E5 - Personal use of employer's vehicles

Either 6(1)(a) or 6(1)(e) & (k) depending on whether or not the vehicle is considered an "automobile". 3. ...
Technical Interpretation - External

16 February 2011 External T.I. 2010-0389561E5 - Transfer of farm property to "ex" daughter-in-law

The TAB went on to point out (at paragraph 13) the potential absurdities if one were to conclude that the in-law relationship continued after death: "... ...
Ruling

2010 Ruling 2010-0360361R3 - Indian LP - 20(1)(c) Deduction

The interest rate on the Limited Partnership Promissory Note will be the prime rate as statistically monitored by the Bank of Canada plus XXXXXXXXXX %. ...

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