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Technical Interpretation - External summary
13 January 2014 External T.I. 2013-0474431E5 - Application of 95(2)(b)(ii) -- summary under Paragraph 95(2)(b)
., the mark-up covers other costs such as employment benefits – and that whether more than that level of markup would result in an offsetting deduction in computing the FAPI of FA "depends on the proper determination of the related profit to be attributed to the activities of the relevant personnel. ...
Ruling summary
2013 Ruling 2013-0487911R3 - Mortgage Investment Corporation -- summary under Section 253.1
. … Opco may advance funds to the LP from time to time for working capital and development… on arm's length commercial terms…. ...
Conference summary
16 June 2014 STEP Roundtable, 2014-0523021C6 - Multiple assessments - STEP Q19 -- summary under Subsection 220(3.1)
. … ...
Technical Interpretation - External summary
4 March 2014 External T.I. 2013-0491981E5 F - Soins à un conjoint inapte -- summary under Business Source/Reasonable Expectation of Profit
. … In Johanne Maurice v. The Queen, 2001 DTC 3710, Mrs. Maurice was receiving amounts in her capacity as a tutor for home help services she personally provided to her mentally incompetent daughter, a minor. ...
Technical Interpretation - External summary
19 August 2015 External T.I. 2015-0589611E5 - loss consolidation arrangements -- summary under Paragraph 111(1)(a)
CRA responded: S3-F6-C1 … paragraph… 1.71… indicates that such loss consolidation arrangements could be undertaken by parties that are related but not affiliated (as well as parties that are both related and affiliated and parties that are affiliated but not related). ...
Technical Interpretation - Internal summary
10 August 2015 Internal T.I. 2014-0527981I7 - Application of 146.1(2.21) to deceased beneficiary -- summary under Subsection 146.1(2.21)
. … [T]he phrase “to or for an individual” in subsection 146.1(2.21) must apply in respect of a living individual and an EAP cannot be paid in respect of a beneficiary once the beneficiary in question is deceased. ...
Conference summary
9 October 2015 APFF Financial Strategies and Instruments Roundtable Q. 9, 2015-0596611C6 F - Transfer 70(6) -- summary under Subsection 70(6)
translated at Q.9 S. 70(6) rollover for replacement property
. … If an executor, in performing the estate administration, is under an obligation to dispose of property or he exercises his power to dispose of the property… subsection 70(6) is not complied with since the property has not vested indefeasibly in the trust. ...
Conference summary
9 October 2015 APFF Roundtable Q. 6, 2015-0595551C6 F - Capital Dividend Account -- summary under Paragraph 87(2)(z.1)
translated at Q. 6 Negative amalgamation effect on combined CDA
(b) of the CDA definition from the receipt of the dividend – so that Holdco can then pay a capital dividend of $1M to its individual shareholder. ...
Conference summary
9 October 2015 APFF Roundtable Q. 6, 2015-0595551C6 F - Capital Dividend Account -- summary under Capital Dividend Account
translated at Q. 6 Negative amalgamation effect on combined CDA
(b) of the CDA definition from the receipt of the dividend – so that Holdco can then pay a capital dividend of $1M to its individual shareholder. ...
Conference summary
24 November 2015 CTF Roundtable Q. 1, 2015-0610691C6 - T2 Late-Filing: Impact on Div. Refund and RDTOH -- summary under Subsection 129(1)
. … As well, the CRA will consider that a dividend recipient’s Part IV tax liability with respect to a dividend received from a connected dividend payer will be determined according to the dividend refund actually received by the dividend payer. ...