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Administrative Policy summary

17 June 2025 STEP Roundtable, Q.5 -- summary under Paragraph 146.4(4)(j)

., government contributions exceed plan holder contributions, annual withdrawals are limited to 10% of the value in the RDSP at the beginning of the year except that CRA has indicated that it may permit withdrawal requests above that limit in circumstances of financial hardship where it is just and equitable to do so. ...
Administrative Policy summary

9 October 2025 APFF Roundtable, Q.14 -- summary under Subparagraph (c)(i)

9 October 2025 APFF Roundtable, Q.14-- summary under Subparagraph (c)(i) Summary Under Tax Topics- Income Tax Act- Section 110.6- Subsection 110.6(1)- Qualified Small Business Corporation Share- Paragraph (c)- Subparagraph (c)(i) the equivalence of cash held to future years’ expenses is insufficient to establish that such cash was used in the business In the course of its active services business, Opco contracted to provide services to an unrelated third party in consideration for $100,000 received in cash at the time of the agreement, of which it expected to use $80,000 to cover ongoing expenses during the three-year term of the contract (for a net profit of $20,000) but with no contractual restriction as to its use of the $80,000 cash. ...
Administrative Policy summary

9 October 2025 APFF Roundtable, Q.15 -- summary under Subparagraph 84.1(2.31)(g)(i)

. If, after consideration of all the facts and circumstances, it were shown that Child would exercise a sufficiently significant power previously exercised by Mr. ...
Administrative Policy summary

P-171R "Distinguishing Between a Joint Venture and a Partnership for the Purposes of Section 273 Joint Venture Election" 24 February 1999 -- summary under Subsection 273(1)

The participant's specified interest could be x % of every product produced or 100% of one product and 0% of the other products.... ...
Administrative Policy summary

GST/HST memorandum 9.4 "Reimbursements" June 2012 -- summary under Subsection 175(1)

There is no employer employee relationship between Company A and the employees of Company B. ...
Administrative Policy summary

Bulletin PST 316 "Bundled Sales and Leases" -- summary under Subsection 26(3)

. Example 2 For $15,000 per month, you lease a restaurant building with affixed machinery (beer tap equipment) and various furniture. ...
Administrative Policy summary

2 December 2014 CTF Roundtable, Q. 4 -- summary under Subsection 212.1(4)

Therefore, the application of subsection 212.1(4) in this case would defeat the objective of section 212.1…. ...
Administrative Policy summary

4 September 2003 Ruling 46189 -- summary under Subparagraph 7(a)(ii)

During Period 2, the s. 7(a)(ii) exemption will not apply to the Base Rents nor will s. 6.1, since the Developer has acquired the Residential Units for the purpose of making supplies of the Units by way of assignment. ...
Administrative Policy summary

AD-18-01: "Taxable Benefit for the Personal Use of an Aircraft" 17 March 2018 -- summary under Subsection 15(1)

It is generally less favourable than that in (cancelled) IT-160R3 under which, for example, the benefit could be computed based on the cost of a first-class ticket in a wider range of circumstances (and for a “small, inexpensive aircraft,” might be based on an economy class fare) and there was no mention of an imputed available-for-use benefit based on the aircraft’s cost. ...
Administrative Policy summary

17 May 2017 Interpretation 174642 -- summary under Subsection 191(3)

It is estimated that during the regular academic session from September to May, more than 10% of the units will be supplied for short-term stays (generating rentals of more than $20 per day) and, during June through August, that 90% or more of the apartment units will be supplied for short-term stays (under one month) with the balance for long-term stays. ...

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