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Technical Interpretation - External summary
16 April 2014 External T.I. 2013-0514521E5 - Employer-paid Personal Trainer and Nutritionist -- summary under Paragraph 6(1)(a)
. … Where counselling services are part of a program provided by a personal trainer or nutritionist, it is our view that the value of any benefit derived from such services would be difficult to separate from the value of any other benefits received or enjoyed under the program. ...
Technical Interpretation - External summary
18 September 2013 External T.I. 2012-0462061E5 F - Amount included in the income of the annuitant -- summary under Subsection 146(8.3)
As a result … provided the amounts withdrawn are from an RRSP where only the annuitant paid premiums, the withdrawals would be included in the computation of the annuitant's income under subsection 146(8). ...
Technical Interpretation - External summary
26 September 2014 External T.I. 2014-0531441E5 - Unfunded LTD plan payment to non-resident employee -- summary under Paragraph 115(2)(c)
. … As such, the amount of LTD Plan payments that would be taxable as income earned by a non-resident employee would be determined in accordance with subsection 115(2) and withholdings under Part XIII would not be applicable… [and] the LTD Plan payments would be subject to withholding under paragraph 153(1)(a)…. ...
Technical Interpretation - External summary
26 September 2014 External T.I. 2014-0531441E5 - Unfunded LTD plan payment to non-resident employee -- summary under Paragraph 153(1)(a)
. … As such, the amount of LTD Plan payments that would be taxable as income earned by a non-resident employee would be determined in accordance with subsection 115(2) and withholdings under Part XIII would not be applicable… [and] the LTD Plan payments would be subject to withholding under paragraph 153(1)(a)…. ...
Conference summary
6 May 2014 May CALU Roundtable, 2014-0523261C6 - Grandfathered status of LIA policy -- summary under LIA Policy
Finally, where a life insurance policy was assigned as security to the lender prior to March 21, 2013 and it is then replaced with a new life insurance policy after that date … this fact, in itself, will not jeopardize the grandfathered status…. ...
Technical Interpretation - External summary
26 September 2014 External T.I. 2014-0531441E5 - Unfunded LTD plan payment to non-resident employee -- summary under Article 18
. … As such… withholdings under Part XIII would not be applicable… [and] the LTD Plan payments would be subject to withholding under paragraph 153(1)(a)…. ...
Technical Interpretation - External summary
7 October 2013 External T.I. 2013-0500941E5 F - Actif utilisé dans une entreprise active -- summary under Qualified Small Business Corporation Share
Before responding negatively, CRA stated (TaxInterpretations translation): … In this situation, 17% of the building is used in an active business carried on by XXXXXXXXXX. ...
Technical Interpretation - Internal summary
7 March 2014 Internal T.I. 2013-0506671I7 F - Subparagraph 104(27)(d)(ii) and paragraph 60(j) -- summary under Subparagraph 104(27)(d)(ii)
. … Consequently, a testamentary trust cannot designate a benefit in its income tax return without ensuring that it constitutes an amount that would have otherwise been eligible under paragraph 60(j) for a beneficiary if the beneficiary had received it. ...
Technical Interpretation - Internal summary
10 January 2014 Internal T.I. 2013-0505911I7 - Meaning of "assembly project" in Brazil Convention -- summary under Article 5
. … Usually…installation is seen as being performed in relation to a tangible property, such as a machine or equipment, and…installation should be the main activity of the project to qualify as an "installation project". ...
Conference summary
11 October 2013 APFF Roundtable, 2013-0495721C6 F - APFF 2013- Round table question 7 -- summary under Shares
. … There is ample authority for the proposition that a trial judge is entitled to arrive at his own opinion as to value.” ...