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Administrative Policy summary
28 February 2019 CBA Roundtable, Q.27 -- summary under Sale
After indicating that “one could argue that the Developer holds legal ownership for the benefit of the Builder and is required to transfer legal ownership … to any third party at the Builder’s request (for example, to the Home Buyer …),” CRA stated: [P]rovided that legal ownership is transferred from the Developer, at the Builder’s direction at Subsequent Closing, to the Home Buyer who is the particular individual with whom the Builder has entered into the Home Buyer Agreement, the CRA will … regard the Builder as having transferred ownership of the House or Unit … to the Home Buyer …. ...
Administrative Policy summary
27 April 2018 Ruling 185888 -- summary under Section 5
. … There are no provisions … to exempt the supply of paramedical services. … The fact that a paramedic may perform certain services on the delegated authority of a physician does not change the nature of the supply. ...
Administrative Policy summary
Memorandum TPM-03 "Downward Transfer Pricing Adjustments, 21 June 2022 -- summary under Subsection 247(10)
Summary of changes from TPM-03 provided at Notice of Policy Update: Publication of the revised TPM-03R
If the taxpayer cannot demonstrate to the CRA’s satisfaction the absence of retroactive tax planning, base erosion and profit shifting strategies, or double non-taxation, the auditor will … recommend the request not be accepted …. ... Therefore, in order for a downward transfer pricing adjustment to be considered appropriate, repatriation must be carried out within 90 days of signing a repatriation agreement (see … TPM-02R ….) 27. ... Appendix A – Examples Example of double non-taxation being addressed through foreign reporting or under MAP 3. ...
Article Summary
Carrie Smit, "Repurchasing Underwater US Dollar Notes", International Tax (Wolters Kluwer), August 2015, No. 83. -- summary under Subsection 39(3)
Unfortunately, the issuer may not be able to apply the foreign exchange loss to offset a portion of the forgiven amount… Comparison with open market purchase]T]he capital gain realized under subsection 39(3) is equal to the excess of the amount for which the obligation was issued over the purchase price to be paid....CRA...has taken the position [fn 4: … 2008-0302511I7....]… that the amount for which the obligation was issued, and the purchase price to be paid, need to be translated into Canadian dollars using the relevant exchange rates at the times such amounts arose. ...
Article Summary
Brent F. Murray, "The General Anti-Avoidance Rule: CRA Discussions on GST Matters", CCH Tax Topics, No. 2191, March 6, 2014, p. 1. -- summary under Subsection 274(4)
CRA misconcepton that no GST avoidance (p. 2) In an internal presentation from the Compliance Programs Branch...that was prepared in September 2006, it was indicated that "misconceptions exist at all levels that tax avoidance does not exist in relation to the Excise Tax Act "…. ...
Article Summary
Steve Suarez, "Canada's 88(1)(d) Tax Cost Bump: A Guide for Foreign Purchasers", Tax Notes International, December 9, 2013, p. 935 -- summary under Subparagraph 88(1)(c.2)(i)
Ownership of Shares in Related Upstream Corporations: a person is deemed to be a specified shareholder of a particular corporation if that person meets the 10 percent share ownership (or deemed share ownership) threshold in any other corporation that both: is related to the first corporation; and has a ''significant direct or indirect interest'' in the first corporation — that is, an ''upstream'' related corporation. ...
Article Summary
Henry Chong, "Canada and FATCA", Tax Management International Journal, 2014, p. 527. -- summary under Section 2
. … [I]nvestment vehicles such as private trusts that do not hold themselves out to the public as investment funds would not appear to be included as Financial Institutions or RCFIs under the expanded definition of that term under the Act but could be RCFIs under the Canada FGA and FFIs under FATCA. ...
Article Summary
Justice Marshall Rothstein, "An Overview of the Supreme Court of Canada", Bulletin for International Taxation (IBFD), January/February 2016, p. 20. -- summary under Stare Decisis
.-- summary under Stare Decisis Summary Under Tax Topics- General Concepts- Stare Decisis Stare decisis usually applies (p. 20) As the Court recently noted: " stare decisis is not a straitjacket that condemns the law to stasis". ...
Article Summary
Paul Dhesi, Korinna Fehrmann, "Integration Across Borders", Canadian Tax Journal, (2015) 63:4, 1049-72 -- summary under Subsection 93(1)
[T]he overall flow-through tax result can be improved if a purchaser is willing to acquire the shares of the CFA | rather than the asset directly. ...
Article Summary
Ian Crosbie, "Recent Transactions of Interest, Part I", 2015 CTF Annual Conference paper -- summary under Subsection 212.3(2)
. … 2) [A]t the same time, a) In consideration for shares in the capital of Whiting (the "consideration") delivered to the Kodiak shareholders by Whiting on behalf of Whiting Bidco, Whiting Bidco issued shares to Whiting with a fair market value equal to the value of the consideration; and b) Whiting Bidco purchased the outstanding Kodiak shares in exchange for the consideration, to be issued directly by Whiting to Kodiak shareholders on behalf of Whiting Bidco…. 5) Whiting Bidco and Kodiak amalgamated (to form "Kodiak Amalco") "with the same effect as if they were amalgamated under...the BCBCA", "except that the separate legal existence of [Kodiak] will not cease and [Kodiak] will survive the Amalgamation". ...