Search - 阿里拍卖 司法拍卖
Results 2451 - 2460 of 3382 for 阿里拍卖 司法拍卖
Technical Interpretation - External summary
11 June 2015 External T.I. 2014-0522641E5 F - Usufruct -- summary under Qualified Farm or Fishing Property
. … At the termination of the usufruct and, thus, of the deemed trust, there is a disposition of property held by the deemed trust in favour of the bare owner. ...
Technical Interpretation - External summary
16 April 2015 External T.I. 2014-0561061E5 - Specified Foreign Property -- summary under Specified Foreign Property
. … Based on the limited description…the digital currency would be held outside of Canada and would not be considered to be used or held exclusively in the course of carrying on an active business. ...
Technical Interpretation - Internal summary
23 July 2014 Internal T.I. 2014-0525231I7 - Foreign tax credit -- summary under Non-Business-Income Tax
Canco paid Japanese income tax on the capital gain reported on such disposition and also reported a capital gain for Canadian tax purposes – but later determined (with CRA's concurrence) that the fair market value of the shares had been nil. ...
Technical Interpretation - External summary
5 February 2013 External T.I. 2012-0465591E5 F - Form T5018 -- summary under Subsection 238(1)
CRA responded: [T]he term "construction" in its ordinary meaning and …[Reg.] 238(1) … are broad enough to include most of the projects that could be qualified as landscaping. ...
Conference summary
10 October 2014 APFF Roundtable, 2014-0538101C6 F - Avantage automobile en vertu de 15(5) -- summary under Paragraph 15(1.4)(c)
. … If the automobile benefit was conferred on Son…in his capacity of employee of the corporation and Son included the value of the benefit in computing his income from employment…no amount would be included in computing income of his father under subsection 15(1)…. ...
Technical Interpretation - Internal summary
25 April 2013 Internal T.I. 2013-0478511I7 F - Distribution à un commanditaire -- summary under Real Estate
. …. If, in the case described, there in fact is an allocation of capital gains of the SEC to its partners, we believe it would be difficult to maintain that they do not retain their character in the hands of the latter, including the Limited Partner. ...
Conference summary
5 October 2012 Roundtable, 2012-0451261C6 F - Foreign entity classification -- summary under Corporation
After summarizing it two-step approach to entity classification, CRA stated: The CRA has not established a list of essential features that a foreign Entity must possess to be classified in any of the different categories of recognized Entities …. ...
Ruling summary
2014 Ruling 2014-0530961R3 - Cross-Border Butterfly -- summary under Subparagraph 55(3.1)(b)(i)
See summary under s. 55(1) – distribution. ...
Conference summary
28 May 2015 IFA Roundtable Q. 7, 2015-0581611C6 - IFA 2015 Q7: Foreign affiliates-surplus adjustments -- summary under Subsection 5905(7.2)
On this basis, while the exempt surplus of FA3 would be reduced to $25, … Merged FA's opening exempt surplus is $200. ...
Technical Interpretation - External summary
2 April 2014 External T.I. 2012-0473151E5 F - Limitation du coût de location d'un véhicule -- summary under Subsection 248(16)
Therefore … if sales taxes are included in the lease charges, the consumption tax amounts recovered in respect of the lease of the vehicle will be included in element E in the formulas under paragraphs 67.3(c) and (d) for the purpose of calculating the limitation in section 67.3. ...