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Technical Interpretation - External

6 July 2004 External T.I. 2004-0077331E5 - allocation of income of estate to heirs

Murphy Section Manager for Division Director International & Trusts Division Income Tax Rulings Directorate Policy and Planning Branch ...
Technical Interpretation - External

28 July 2004 External T.I. 2004-0059261E5 - Permanent Establishment

It has approximately XXXXXXXXXX % of its workforce at customer sites in Quebec and less than XXXXXXXXXX% of its workforce in provinces other than Quebec and Ontario. ...
Technical Interpretation - External

17 September 2004 External T.I. 2004-0076741E5 - medical expenses renovations

This provision includes as qualifying medical expenses, amounts expended "... for reasonable expenses relating to renovations or alterations to a dwelling of the patient who lacks normal physical development or has a severe and prolonged mobility impairment, to enable the patient to gain access to, or to be mobile or functional within, the dwelling"... ...
Technical Interpretation - External

17 September 2004 External T.I. 2004-0083161E5 - ACB of shares under administration of an estate

Murphy Section Manager for Division Director International & Trusts Division Income Tax Rulings Directorate Policy and Planning Branch ...
Technical Interpretation - External

15 November 2004 External T.I. 2004-0075401E5 - Sale of Common Property-Principal Residence

., details of the strata plan filed with the government, particulars regarding local municipal zoning bylaws at relevant times (past & present), accurate facts surrounding the history of the property including the expropriation, house demolition, green space requirements, etc.) to determine if the sale of the vacant lot could be treated as a disposition of part of the strata owners' principal residences. ...
Technical Interpretation - External

1 December 2004 External T.I. 2003-0046171E5 - Contribution to Testamentary Trust

The relevant part of the definition reads as follows: "testamentary trust" in a taxation year means a trust or estate that arose on and as a consequence of the death of an individual (including a trust referred to in subsection 248(9.1)), other than [...] ...
Technical Interpretation - External

11 January 2005 External T.I. 2004-0103601E5 - Test Wind Turbine - Proposed Amendments

Chief- Engineering, Technical & Research Team Industrial Programs Division Office of Energy Efficiency 580 Booth St., 18th Floor Ottawa ON K1A 0E4 ...
Technical Interpretation - External

29 March 2001 External T.I. 2001-0071395 - NORTHERN RESIDENTS DEDUCTION

Our Comments Question 1 The northern residents deduction under paragraph 110.7(1)(a) of the Act is computed by multiplying a specified percentage by " an amount received, or the value of a benefit received or enjoyed, in the year by the taxpayer in respect of the taxpayer's employment in the particular area by a person with whom the taxpayer was dealing at arm's length in respect of travel expenses incurred by the taxpayer or another individual who was a member of the taxpayer's household during the part of the year in which the taxpayer resided in the particular area. ...
Technical Interpretation - External

8 May 2001 External T.I. 2000-0057405 - Exempt RPP Payments

We are enclosing the pamphlet entitled “Electing Under Section 217 of the Income Tax Act plus the guide entitled “Genera Income Tax and Benefit Guide for Non-Residents and Deemed Residents of Canada 2000”. ...
Technical Interpretation - External

9 May 2001 External T.I. 2001-0070695 - PARTNERSHIP ; ACB

However, we do recognize that there is a possibility of double taxation in some situations, and, as we have previously stated (see, for example, the attached excerpt from Income Tax Technical News), we are willing- in the context of an advance income tax ruling, where all relevant facts are available to consider applying the law so that double taxation is avoided. ...

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