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Technical Interpretation - Internal summary
19 September 2016 Internal T.I. 2016-0641841I7 - Employee stock option rules -- summary under Subsection 7(2)
. … [S]ubsection 7(2) cannot apply any earlier than when a specific number of shares have been allocated to an identifiable employee pursuant to a legally binding agreement to issue or sell shares. ...
Technical Interpretation - Internal summary
9 June 2011 Internal T.I. 2011-0396721I7 F - Déduction - habitants de régions éloignées -- summary under Subsection 110.7(1)
. … [I]n the situation you described, an individual who resides in a prescribed northern or intermediate zone for a period of at least six months and who has a 35-day work cycle in the said zone followed by an 8-day leave in his other residence at XXXXXXXXXX would be entitled to the deduction provided for in section 110.7. ...
Technical Interpretation - Internal summary
7 January 2011 Internal T.I. 2010-0387011I7 F - DPA dans une année prescrite -- summary under Revising Claims
…[T]he CRA should not accept the adjustment request … as it would result in changes to the tax assessment for Year 1, which is a statute-barred year. ...
Technical Interpretation - External summary
19 May 2010 External T.I. 2010-0364131E5 F - Issuance - Discretionary shares -- summary under Subsection 15(1)
. – which, in turn, could engage s. 74.1(1) where the subscriber was X’s spouse. ...
Technical Interpretation - External summary
19 May 2010 External T.I. 2010-0364131E5 F - Issuance - Discretionary shares -- summary under Paragraph 69(1)(b)
., by X rather than Opco) where CRA would apply s. 69(1)(b) and Kieboom on the basis that X had disposed of an interest in Opco to the Class B share subscriber for the FMV of that interest – which, in turn, could engage s. 74.1(1) where the subscriber was X’s spouse. ...
Technical Interpretation - External summary
19 May 2010 External T.I. 2010-0364131E5 F - Issuance - Discretionary shares -- summary under Subsection 74.1(1)
CRA then stated: [I]f X disposed of any right or interest in Opco to X's spouse … we could also argue that the attribution rules in subsection 74.1(1) would apply to reallocate to X any dividends paid on the Class B shares held by X's spouse. ...
Technical Interpretation - Internal summary
6 April 2010 Internal T.I. 2009-0343091I7 F - Montant pour enfant -- summary under Paragraph 118(4)(b)
. … Since Mr. A and Ms. B lived in separate self-contained domestic establishments during the period of the year in which they lived apart, the concept of the same "self-contained domestic establishment" in 118(4)(b) does not restrict the right of Mr. ...
Technical Interpretation - External summary
16 June 2010 External T.I. 2009-0344861E5 F - Actifs de la Catégorie 16 -- summary under Paragraph 16(e)
. … Subparagraph (e)(ii) of the definition of automobile refers to pick-up trucks and/or vans the use of which, in the taxation year in which they are acquired or leased, are all or substantially all for the transportation of goods, equipment or passengers in the course of gaining or producing income. ...
Technical Interpretation - External summary
11 June 2010 External T.I. 2010-0354881E5 F - Traitement fiscal de la FNACC -- summary under Subsection 20(16)
. … …[T]o the extent that the CFVP was the only depreciable property included in Class 10, the change in use of the CFVP results in no property being included in Class 10. ...
Technical Interpretation - Internal summary
30 September 2010 Internal T.I. 2010-0373901I7 F - Bigamie fiscale - transfert de biens au décès -- summary under Subparagraph 40(4)(b)(i)
30 September 2010 Internal T.I. 2010-0373901I7 F- Bigamie fiscale- transfert de biens au décès-- summary under Subparagraph 40(4)(b)(i) Summary Under Tax Topics- Income Tax Act- Section 40- Subsection 40(4)- Paragraph 40(4)(b)- Subparagraph 40(4)(b)(i) application of s. 40(4)(b)(i) by both surviving spouse re House A and surviving common-law partner re House B – but not for overlapping years The taxpayer lived with his spouse in Immovables A, but thereafter commenced to live separate and apart from her, but did not divorce from her, and instead lived in a conjugal relationship with another (a common-law partner) in Immovable B until his death. ...