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Technical Interpretation - External

18 December 2012 External T.I. 2012-0468301E5 - Clarification of Class 43.2 Project Eligibility

Manager Resources Section Income Tax Rulings Directorate Legislative Policy & Regulatory Affairs Branch ...
Technical Interpretation - External

22 July 2015 External T.I. 2015-0576461E5 - Clergy Residence Deduction

XXXXXXXXXX ` 2015-057646 T. Baltkois July 22, 2015 Dear XXXXXXXXXX Re: Clergy residence deduction We are writing in response to your correspondence concerning whether a school chaplain employed by XXXXXXXXXX (College) may claim the clergy residence deduction provided by paragraph 8(1)(c) of the Income Tax Act (Act). ...
Technical Interpretation - External

31 August 2015 External T.I. 2015-0582411E5 - Standby charge - employee required to use vehicle

Although it is a question of fact whether the employee's travel is personal or employment-related, it is the CRA's longstanding position, as noted in Chapter 2 of Guide T4130, Employer's Guide – Taxable Benefits and Allowances, that travelling between an employee's home and his or her regular place of employment (RPE) is personal travel. ...
Technical Interpretation - External

15 June 2015 External T.I. 2015-0577801E5 - Deferred Salary Leave Plan and Maternity Leave

The Regulations state that if the leave of absence (" Leave Period") is for the purpose of attending a designated educational institution on a full-time basis, the leave must be for at least 3 consecutive months. ...
Technical Interpretation - External

4 March 2013 External T.I. 2011-0428661E5 - trust payments to minor

4 March 2013 External T.I. 2011-0428661E5- trust payments to minor CRA Tags 104(18) 80 104(24) 75(2) Principal Issues: Discussion of making payments or making amounts payable to or on behalf of a minor from a trust & the application of 75(2) Position: No change in previous positions Reasons: Appears to be actual fact situation, so general comments given XXXXXXXXXX Lena Holloway, CA 613-957-8968 2011-042866 March 4, 2013 Dear XXXXXXXXXX: Re: Trust for Minor This is in reply to your email communication dated November 18, 2011 requesting our comments on the application of subsection 104(18) of the Income Tax Act (the "Act"). ...
Technical Interpretation - External

10 August 2012 External T.I. 2012-0436411E5 - Accumulated Profits

The exception to the direct use test for borrowed money used by a corporation to redeem shares, return capital or pay dividends is described in paragraph 23 of IT-533 as follows: 23. ...
Technical Interpretation - External

18 August 2014 External T.I. 2014-0528001E5 - Fiscal period of a partnership

Moore for Director Partnerships & Corporate Financing Section International Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...
Technical Interpretation - External

8 October 2014 External T.I. 2014-0539231E5 - Indian Employment Income

An objection is filed by using one of these options: online submission, by accessing "My Account" from the CRA website; select the option "Register my formal dispute"; or completing Form T400A, Objection – Income Tax available on the CRA website at: http://www.cra-arc.gc.ca/E/pbg/tf/t400a/t400a-12e.pdf. ...
Technical Interpretation - External

8 September 2014 External T.I. 2014-0529231E5 - Partnership to Sole Proprietorship

Moore for Director Partnerships & Corporate Financing Section International Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...
Technical Interpretation - External

5 December 2013 External T.I. 2013-0485661E5 - U.K. ISA held by a temporary resident of Canada

On immigration to Canada, paragraphs 128.1(1)(b) and (c) of the Act generally provide for a deemed disposition of the individual's property (other than property described in subparagraphs 128.1(1)(b)(i) to– (v), – not applicable to this scenario) immediately before the time of immigration to Canada for proceeds equal to fair market value, and a deemed reacquisition of such property at a cost equal to the proceeds of disposition. ...

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