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Technical Interpretation - External summary

15 July 2024 External T.I. 2023-0990221E5 - Principal Residence Exemption-Condo parking Spaces -- summary under Principal Residence

. [I]t is our view that the First Parking Space is a component of the housing unit (i.e., the Condo). ...
Ruling summary

2022 Ruling 2021-0919101R3 - Ruling Letter -- summary under Disposition

However, on the death of Daughter2, ½ of the Fund property had been distributed in accordance with the Fund terms to her issue. ...
Conference summary

10 October 2024 APFF Financial Strategies and Instruments Roundtable Q. 1, 2024-1023641C6 - Intercompany loans and taxable benefits -- summary under Subsection 15(1)

. Subsection 15(1) could apply, for example, if at the time the loan is made by Aco, the other corporation (“Bco”) is unable to repay the loan and/or provide reasonable security, with the result that the value of Aco would be impaired. ...
Conference summary

10 October 2024 APFF Financial Strategies and Instruments Roundtable Q. 8, 2024-1023591C6 F - NERDTOH and foreign investment income -- summary under Variable B

(a)(i) to (iii) of the definition of NERDTOH in s. 129(4)- always correspond to the foreign tax deduction (FTD) otherwise claimed by the corporation under s. 126(1) in respect of its foreign non-business income, reduced by 8% of the foreign investment income (FII), even if no tax is withheld by the foreign country on such investment income for example, on the sale of shares of a foreign public company listed on a foreign stock exchange resulting in a capital gain? ...
Conference summary

10 October 2024 APFF Financial Strategies and Instruments Roundtable Q. 10, 2024-1027331C6 F - Distribution of life insurance - 107(2) and 148(7) -- summary under Subsection 107(2)

Summary of 10 October 2024 APFF Financial Strategies & Instruments Roundtable, Q.10 under s. 148(7). ...
Technical Interpretation - Internal summary

14 September 2000 Internal T.I. 2000-0035797 F - ALLOCATION DE SEJOUR -- summary under Subparagraph 6(6)(a)(i)

. [T]he term “maintained” must be interpreted as meaning “incurred expenses in respect of the self-contained domestic establishment (residence)”. ...
Technical Interpretation - External summary

30 November 2000 External T.I. 2000-0026615 F - GAAR -- summary under Subsection 83(2.1)

CCRA stated: [T]he Agency's position is that a corporation that redeems shares held by one of its shareholders may pay its entire capital dividend account to that shareholder, provided that subsection 83(2.1) does not apply. ...
Technical Interpretation - External summary

28 November 2000 External T.I. 2000-0027835 F - regime prive d'assur.-maladie -- summary under Paragraph 118.2(2)(q)

. Expenses paid to a “private health services plan” as a premium, contribution or other consideration in respect of, among others, the individual or the individual's spouse generally qualify as medical expenses under paragraph 118.2(2)(q) except to the extent that the payment was deducted by the individual as a business expense under subsection 20.01(1). ...
Technical Interpretation - External summary

19 February 2025 External T.I. 2018-0744821E5 F - Régime d’assurance collective - groupe de personne -- summary under Subparagraph 6(1)(a)(i)

. [F]or an individual disability insurance policy to be a component of a group insurance plan, it must be determined whether the level of benefits and the ratio of contributions to the plan shared by the employer and the employee are similar to those of the other employees covered by the same plan. ...

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