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Technical Interpretation - External summary

25 January 2018 External T.I. 2017-0717561E5 - specified small business corporation -- summary under Small Business Corporation

Cash balances which accumulate only to be depleted in accordance with the annual seasonal fluctuations of the business will generally qualify but a permanent balance in excess of the company's reasonable working capital needs will generally not qualify. ...
Technical Interpretation - Internal summary

7 February 2018 Internal T.I. 2017-0711961I7 - Withholding on RCA payment to partnership -- summary under Subsection 103(6)

. Since Schedule I does not address this situation, the Payment is subject to subsection 106(1). ...
Technical Interpretation - Internal summary

7 February 2018 Internal T.I. 2017-0711961I7 - Withholding on RCA payment to partnership -- summary under Subsection 106(1)

In rejecting the employer’s position, the Directorate stated that “subsection 96(1) ensures that the members of the partnership are taxable on their respective share of the partnership’s income” and that in applying Reg. 106(1), “the amount to be withheld from the [withdrawal] Payment should be equal to the total amount of tax that may reasonably be expected to be payable under the Act by the members of the employer partnership with respect to the Payment.” ...
Technical Interpretation - External summary

24 July 2017 External T.I. 2017-0698191E5 - Gift of securities by executors of a will -- summary under Subparagraph 38(a.1)(ii)

. [T]he taxable capital gain in respect of any subsequent increase in value of the mutual fund units from the date of death to the date of disposition by the GRE to the qualified donee will also be equal to zero pursuant to subparagraph 38(a.1)(i). ...
Technical Interpretation - Internal summary

16 August 2017 Internal T.I. 2017-0701291I7 - Exclusive Distributorship Rights -- summary under Restrictive Covenant

The right to distribute relates to a specific presentation and only for the specified purpose…. ...
Technical Interpretation - External summary

19 January 2018 External T.I. 2017-0683501E5 - Flow-Through Shares -- summary under Exemption Threshold

However, CRA went on to indicate that the taxpayer’s exemption threshold in this situation would be nil “it is necessary for the taxpayer to have acquired a flow-through share (or certain partnership interests …) in order for a taxpayer to have an exemption threshold in respect of a flow-through share class of property to which subsection 40(12) of the Act would apply.” ...
Conference summary

6 October 2017 APFF Financial Strategies and Instruments Roundtable Q. 10, 2017-0705201C6 F - Capital loss - repayment of loan -- summary under Property

See also 2008-0280111I7.
CRA indicated that the issue here is whether the U.S. dollars received by the borrower under the new loan are identical property to the foreign currency that it was deemed to have disposed of under s. 39(2), and noted that under the "property" definition in s. 248(1), “money could constitute property unless a contrary intention is evident” but then stated: However, the CRA's position is not to consider money to be identical property for the purposes of subparagraph 40(2)(g)(i) or subsections 40(3.3) and (3.4) in a circumstance such as this where a taxpayer sustains a loss under subsection 39(2). ...
Ruling summary

2016 Ruling 2015-0616291R3 - Cross-Border Butterfly -- summary under Permitted Exchange

Foreign Pubco then drops Foreign DC into a new subsidiary (Foreign TC) of a newly-formed LLC subsidiary of Foreign Pubco (New LLC to which other significant foreign assets already have been contributed) pursuant to a three-party exchange agreement under which Foreign Pubco transfers Foreign DC directly to Foreign TC, Foreign TC issues shares to New LLC, and New LLC issue units to Foreign Pubco. ...
Conference summary

6 October 2017 APFF Roundtable Q. 3, 2017-0709011C6 F - Désignation d’un bien comme résidence principale -- summary under Paragraph (c)

. A written copy of the individual’s election should be retained for future reference…. ...
Conference summary

6 October 2017 APFF Financial Strategies and Instruments Roundtable Q. 2, 2017-0710681C6 F - Withdrawal of RRSP over-contributions after death -- summary under Subsection 146(8.2)

The executor of a deceased annuitant's estate should simply indicate the amount claimed in line 232 of the terminal return of the deceased annuitant and use the space to the left of the line to indicate that it is a deduction for the refund of unused RRSP contributions. ...

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