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Technical Interpretation - External summary
16 June 2010 External T.I. 2009-0344861E5 F - Actifs de la Catégorie 16 -- summary under Paragraph 16(e)
. … Subparagraph (e)(ii) of the definition of automobile refers to pick-up trucks and/or vans the use of which, in the taxation year in which they are acquired or leased, are all or substantially all for the transportation of goods, equipment or passengers in the course of gaining or producing income. ...
Technical Interpretation - External summary
11 June 2010 External T.I. 2010-0354881E5 F - Traitement fiscal de la FNACC -- summary under Subsection 20(16)
. … …[T]o the extent that the CFVP was the only depreciable property included in Class 10, the change in use of the CFVP results in no property being included in Class 10. ...
Technical Interpretation - External summary
4 May 2010 External T.I. 2009-0329391E5 F - Provision pour retour de marchandises -- summary under Paragraph 18(1)(e)
After indicating that no reserve under s. 20(1)(m) was available, and confirming its position in IT-215R, para. 13, CRA stated: [A] clause permitting the return of goods not sold by customers is not a clause contemplated by paragraph 13 … where title passes to the purchaser upon delivery, well before the expiry of the time limit for the return of goods. ...
Technical Interpretation - External summary
5 November 2010 External T.I. 2010-0383871E5 F - Crédit d'impôt pour emploi à l'étranger -- summary under Paragraph 122.3(1)(b)
. … For example, if the qualifying period is 14 continuous months, and assuming that the employment duties are performed consistently over the period, the employee would not normally be expected to spend more than 1.4 months (10% of 14) in Canada performing the duties of employment that would otherwise qualify for the OETC. ...
Technical Interpretation - External summary
4 October 2010 External T.I. 2010-0376111E5 F - Frais de scolarité - formation continue -- summary under Clause 118.5(1)(a)(ii.2)(B)
Whether it is reasonable to consider that the reason for an individual's registration at an institution is to enable the individual to acquire or improve the skill necessary to carry on an occupation is a question of fact …. ...
Technical Interpretation - External summary
19 August 2010 External T.I. 2009-0344111E5 F - Résidence Société Capital-Risque - Conv Can-France -- summary under Article 4
It should be noted that a VCC may still be taxed in France on its gains from the disposal of securities which have remunerated it for its contribution of ancillary activities, as well as on income realized in accordance with the company's objects but not coming from the portfolio, such as profits from the disposal of movable or immovable property, and subsidies, all as described … above. ...
Technical Interpretation - External summary
27 July 2010 External T.I. 2010-0364841E5 F - Questions relatives à une séparation -- summary under Paragraph 118(1)(b)
27 July 2010 External T.I. 2010-0364841E5 F- Questions relatives à une séparation-- summary under Paragraph 118(1)(b) Summary Under Tax Topics- Income Tax Act- Section 118- Subsection 118(1)- Paragraph 118(1)(b) two separated spouses living under the same roof required to agree on which one claims the s. 118(1)(b) credit After indicating that it appeared that the correspondent was living separate and apart from the correspondent’s spouse notwithstanding their living under the same roof, CRA stated: [E]ither you or your spouse would be able to claim the wholly dependant person [“equivalent to spouse”] credit under paragraph 118(1)(b) in respect of one of your children, to the extent that the married or common-law partner credit under paragraph 118(1)(a) is not claimed and you were not supporting or dependent on your spouse at any time in the year …. ...
Technical Interpretation - External summary
28 June 2010 External T.I. 2009-0350241E5 F - Crédit d'impôt pour investissement du Québec -- summary under Paragraph 13(7.1)(f)
. … [T]he corporation is entitled to receive this credit for the purposes of paragraph 13(7.1)(f) when the conditions of the first paragraph of section 1029.8.36.166.43 of the TA are satisfied, that is, at the end of the taxation year in which it claims the credit. ...
Technical Interpretation - External summary
22 March 2011 External T.I. 2010-0391131E5 F - Gains ouvrant droit à pension - RPC/RRQ -- summary under Subsection 200(1)
. … [D]eductions for contributions to the Québec Pension Plan must therefore begin to be deducted from the first pay of the month following the month in which the employee reaches the age of 18 years and the amount to be shown in Box 26 of the T4 slip must be recognized from that same time. ...
Technical Interpretation - External summary
9 June 2010 External T.I. 2009-0342081E5 F - Associé déterminé -- summary under Specified Member
. … [T]he more Mr. X is involved in the management and/or day-to-day operations of the SENC, the less likely it is that Trust X will be considered a specified member within the meaning of subsection 248(1). ...