Search - 阿里拍卖 司法拍卖

., the requirement that all or substantially all of the interest and financing expenses of an entity be paid to persons other than tax-indifferent investors, and is exploring some ways that they could be potentially relaxed without compromising the integrity of the rules – and is also interested in exploring whether most of the requests for specific carve-outs, for sectors or types of businesses, could be appropriately dealt with, through an expansion of the excluded entity definition, and of the availability of the group ratio rule. ...

These are additions to our set of 2,089 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 17 ½ years of releases of such items by the Directorate. ...

Bundle Date Translated severed letter Summaries under Summary descriptor 2004-10-29 8 October 2004 Internal T.I. 2004-0093371I7 F- Crédit d'impôt à l'investissement & impôt minimum Income Tax Act- Section 127- Subsection 127(5)- Paragraph 127(5)(a)- Subparagraph 127(5)(a)(ii) carryback of ITCs from year where the taxpayer was subject to minimum tax 19 October 2004 Internal T.I. 2004-0094971I7 F- Programme de formation admissible Income Tax Act- Section 118.6- Subsection 118.6(1)- Qualifying Educational Program “period” referred to the times at which the individual was receiving income from employment 28 September 2004 Internal T.I. 2004-0079801I7 F- Pension alimentaire Income Tax Act- Section 56.1- Subsection 56.1(4)- Support Amount settlement of support arrears are not deductible or includible 30 September 2004 Internal T.I. 2004-0083301I7 F- Entreprises distinctes Income Tax Act- Section 4- Subsection 4(1)- Paragraph 4(1)(a) 2 different centres were branches of the same business 30 September 2004 Internal T.I. 2004-0085051I7 F- Intérêts et indemnité additionnelle Income Tax Act- Section 12- Subsection 12(1)- Paragraph 12(1)(c) indemnity under CCQ Art. 1619 was pre-judgment interest Income Tax Act- Section 129- Subsection 129(4)- Income or Loss interest on damages relating to lost business was active business income 19 October 2004 Internal T.I. 2004-0085711I7 F- Dommages suite à une entente hors cour Income Tax Act- Section 248- Subsection 248(1)- Retiring Allowance amount received in settlement of grievances and on agreeing to retire was a retiring allowance in the absence of evidence that it was for harassment or unpaid wages Income Tax Act- Section 8- Subsection 8(1)- Paragraph 8(1)(n) required repayment of excess amount of wage loss insurance previously received could give rise to s. 8(1)(n) deduction 20 October 2004 Internal T.I. 2004-0086501I7 F- Droits compensateurs Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(vv) posting of bonds for US countervailing duties did not constitute their being “paid” for s. 20(1)(vv) purposes Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(e) obligation to repay suppliers for extra US countervailing duties charge made to them was contingent until a board decision reversed such duties 8 October 2004 APFF Roundtable Q. 11, 2004-0090791C6 F- Maladies graves et soins de longue durée Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a)- Subparagraph 6(1)(a)(i) sickness plan can comprise individual critical illness policies Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(f) periodic payments under long-term care insurance are not taxable Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Income-Producing Purpose premiums for critical illness policies and individual long-term care policies for senior employees are deductible ...

These are additions to our set of 2,125 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 17 ¾ years of releases of such items by the Directorate. ...

These are additions to our set of 2,134 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 17 ¾ years of releases of such items by the Directorate. ...

These are additions to our set of 2,143 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 17 ¾ years of releases of such items by the Directorate. ...

These are additions to our set of 2,151 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 17 ¾ years of releases of such items by the Directorate. ...

These are additions to our set of 2,216 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 18 ½ years of releases of such items by the Directorate. ...

These are additions to our set of 2,257 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 18 ¾ years of releases of such items by the Directorate. ...

These are additions to our set of 2,271 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 18 ¾ years of releases of such items by the Directorate. ...