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Technical Interpretation - External summary

13 February 2017 External T.I. 2015-0570011E5 - Compensation by non-resident-loss of rental income -- summary under Paragraph 212(1)(d)

. When an amount is paid to a taxpayer in a year to compensate for the loss of rental income, [CRA] would generally consider the compensation to be rental income for that year. ...
Technical Interpretation - Internal summary

11 September 2015 Internal T.I. 2015-0586301I7 - Premiums received on re-opening of debt -- summary under Variable E

. [T]he premiums received by the Taxpayer could now fall within amended variable E of the definition of CEC, assuming that the amounts…have [not] reduced the amount of an outlay or expense, (i.e., …if a reduction to paragraph 20(1)(c) did not apply as discussed above.) ...
Technical Interpretation - External summary

14 March 2017 External T.I. 2016-0627311E5 F - Deduction of contribution to an IPP or RCA -- summary under Salary Deferral Arrangement

. In general, supplementary pension benefits are considered to be reasonable when the terms of the supplemental pension plan are substantially the same as those of the IPP. ...
Technical Interpretation - External summary

14 March 2017 External T.I. 2016-0656101E5 F - Death Benefit -- summary under Death Benefit

. After indicating that when the amount was recorded in the minutes did not affect its character, CRA stated that “the payment of the death benefit may be staggered over more than one taxation year.” ...
Technical Interpretation - External summary

31 March 2017 External T.I. 2016-0630351E5 - Return of a gift -- summary under Subsection 118.1(26)

. Where the original property is returned, the taxpayer is deemed not to have disposed of the property nor to have made a gift. ...
Technical Interpretation - External summary

31 March 2017 External T.I. 2016-0630351E5 - Return of a gift -- summary under Charitable Foundation

. [T]he determination of whether the gift of the life insurance policy to the foundation was subject to a condition subsequent or whether the foundation can legally return the life insurance policy is a question of law and beyond the scope of this technical interpretation. ...
Conference summary

26 April 2017 IFA Roundtable Q. 5, 2017-0691121C6 - Foreign tax credit Brazilian interest on equity -- summary under Subsection 91(4.7)

If the Brazilian affiliate had a chain of other foreign affiliates under it, that could also by reason of the chain rules result in the denial of FAT in respect of FAPI for those underlying subsidiaries or for subsidiaries up above, as well. ...
Technical Interpretation - Internal summary

9 August 2016 Internal T.I. 2014-0526171I7 - Resettlement of a Trust -- summary under Paragraph 111(1)(a)

. [T]he transaction changed the whole substratum or “raison d’etre” of the Trust. ...
Technical Interpretation - External summary

15 May 2017 External T.I. 2016-0645891E5 F - Services rendered to a State -- summary under Article 18

. [T]he exercise by a person of duties as a nurse within the Swiss healthcare sector, which is essentially dedicated to the provision of services for the benefit of the community as a whole, does not generally [so] qualify…. ...

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