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Technical Interpretation - External summary
11 June 2015 External T.I. 2014-0522641E5 F - Usufruct -- summary under Qualified Farm or Fishing Property
. … At the termination of the usufruct and, thus, of the deemed trust, there is a disposition of property held by the deemed trust in favour of the bare owner. ...
Technical Interpretation - External summary
16 April 2015 External T.I. 2014-0561061E5 - Specified Foreign Property -- summary under Specified Foreign Property
. … Based on the limited description…the digital currency would be held outside of Canada and would not be considered to be used or held exclusively in the course of carrying on an active business. ...
Technical Interpretation - External summary
5 February 2013 External T.I. 2012-0465591E5 F - Form T5018 -- summary under Subsection 238(1)
CRA responded: [T]he term "construction" in its ordinary meaning and …[Reg.] 238(1) … are broad enough to include most of the projects that could be qualified as landscaping. ...
Technical Interpretation - External summary
2 April 2014 External T.I. 2012-0473151E5 F - Limitation du coût de location d'un véhicule -- summary under Subsection 248(16)
Therefore … if sales taxes are included in the lease charges, the consumption tax amounts recovered in respect of the lease of the vehicle will be included in element E in the formulas under paragraphs 67.3(c) and (d) for the purpose of calculating the limitation in section 67.3. ...
Technical Interpretation - External summary
11 July 2013 External T.I. 2013-0490591E5 F - Montant pour une personne à charge -- summary under Subsection 2(1)
…[T]he sole fact of the non-resident taxpayer being in a conjugal relationship with the Other Person would not make him a resident of Canada …. ...
Technical Interpretation - External summary
6 May 2009 External T.I. 2008-0295581E5 F - Bourses et aide financière aux médecins -- summary under Paragraph 56(1)(n)
These sums must be reported on a T4A slip …. ...
Technical Interpretation - External summary
19 July 2013 External T.I. 2012-0458961E5 F - Stock option, cashless exercise -- summary under Paragraph 7(1)(a)
After referring to Guide T4130, p. 24 and stating that the s. 7(1)(a) benefit is computed on the basis of the shares' fair market value "at the moment of their acquisition," CRA stated (TaxInterpretations translation): … [I]n the context of a short sale, the CRA is generally of the view that an employee has acquired the shares of the employer at the moment the employer transfers the shares to the employee and they are paid for. ...
Technical Interpretation - External summary
24 June 2015 External T.I. 2015-0565951E5 F - Legatee by particular -- summary under Subsection 104(13)
. … The legatee by particular title must include it in computing income under subsection 104(13). ...
Technical Interpretation - External summary
10 April 2014 External T.I. 2013-0514321E5 - Donated vacation -- summary under Paragraph 6(1)(a)
. … [However] it is the practice of the Canada Revenue Agency not to assess the same income twice. ...
Technical Interpretation - External summary
9 July 2015 External T.I. 2013-0475421E5 - Section 94.2 -- summary under Subsection 220(2.1)
CRA went on to state: … [A] failure to report income as required, and false statements or omissions, in respect of prescribed reporting requirements may result in substantial penalties under section 162 or 163. ...