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Technical Interpretation - External summary

7 December 1999 External T.I. 1999-0006715 - Right to object and appeal -- summary under Section 242

. 460354 Ontario Inc. (92 DTC 6534) and Hadi Saraf… (94 DTC 6229), …[involving] the Ontario Business Corporations Act, held that an assessment is an administrative action and therefore a dissolved corporation may be assessed or reassessed, provided the relevant time limit has not expired. ...
Technical Interpretation - External summary

4 July 2012 External T.I. 2011-0429601E5 F - Roulement et société de personnes -- summary under Subsection 97(2)

. [T]wo partnerships may achieve a certain form of merger, if each of them distributes all of its property to its partners, in accordance with paragraph 98(3), and if each partner subsequently invests the property so received in a new partnership in accordance with subsection 97(2). ...
Technical Interpretation - External summary

28 June 2010 External T.I. 2009-0329511E5 - United States - Dividend Withholding Rate -- summary under Article 29A

. Under subparagraph 2(a) [of Article X], the S-Corp would be considered to own the shares of Canco owned by the US LLC.... ...
Technical Interpretation - External summary

12 August 2010 External T.I. 2010-0370551E5 F - Tuck Under Transaction - Tremblay Decision -- summary under Subsection 84(2)

After noting in its summary that Tremblay... contains a strong dissent based on... ...
Technical Interpretation - External summary

26 June 2012 External T.I. 2011-0417391E5 F - Bien remis à une fiducie -- summary under Testamentary Trust

Consequently, whether such capital or income interest in the inter vivos trust is a future or conditional interest, a trust established by will would lose its status as a testamentary trust within the terms of subsection 108(1) or not acquire that status in the first place- if it received an interest in an inter vivos trust. ...
Technical Interpretation - External summary

26 June 2012 External T.I. 2011-0417391E5 F - Bien remis à une fiducie -- summary under Subsection 248(25)

In finding that the purported testamentary trust would not qualify because its contingent interest in the inter vivos trust was not property contributed to it by the deceased, CRA stated: [W]hether such capital or income interest in the inter vivos trust is a future or conditional interest, a trust established by will would lose its status as a testamentary trust within the terms of subsection 108(1) or not acquire that status in the first place- if it received an interest in an inter vivos trust. ...
Technical Interpretation - External summary

15 November 2012 External T.I. 2012-0456201E5 F - Frais médicaux - calcul et dépenses non admissibles -- summary under Subsection 118.2(1)

. [T]o be eligible as medical expenses for the purposes of the METC, the expenses must be incurred, paid for, and evidenced by a receipt within the same 12-month period ending in a taxation year. ...
Technical Interpretation - External summary

15 August 2014 External T.I. 2014-0532941E5 - T5 reporting obligations -- summary under Subsection 201(1)

. T5 slips will also have to be issued when interest is paid by the Brokers to their Clients. ...
Technical Interpretation - External summary

9 April 2013 External T.I. 2012-0461051E5 F - Employee of an international organization -- summary under Subsection 126(3)

After finding that the individual’s income could not be excluded from income through a deduction under s. 110(1)(f)(iii) and was not exempt under s. 81(1)(a) (given the individual's continued Canadian residency), CRA went on to indicate that s. 126(3) could provide a credit, stating: We are of the view that XXXXXXXXXX constitutes an "international organization" within the meaning of subsection 2(1) of the [Foreign Missions and International Organizations Act] in that it includes XXXXXXXXXX states and governments …[and] no non-governmental organization is admitted as a member …. ...
Technical Interpretation - External summary

31 March 2014 External T.I. 2013-0513191E5 - Director/Executor liability -- summary under Subsection 159(3)

. Finally, before making any distributions from the estate, the executor is required to obtain a clearance certificate, pursuant to subsection 159(2)…. ...

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