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Technical Interpretation - External summary
24 April 2015 External T.I. 2014-0560401E5 - Subsections 15(2) and 227(6.1) and Part XIII tax -- summary under Subsection 15(2.6)
Therefore … if the Debt is subsequently repaid to Parentco, Debtor may be entitled to a refund of the Part XIII tax previously assessed. ...
Technical Interpretation - External summary
11 July 2013 External T.I. 2013-0490591E5 F - Montant pour une personne à charge -- summary under Subparagraph 118(1)(b)(ii)
CRA responded: … Mr. would not meet the conditions of paragraph 118(1)(b) since, on the one hand, during the part of the year of separation in which he lived separate and apart from Ms., neither of the two children lived with him and, on the other hand, he lived with Ms. during the other part of the year of separation. ...
Technical Interpretation - External summary
18 September 2012 External T.I. 2012-0442581E5 F - Fiducie au profit d'un athlète amateur -- summary under Subsection 143.1(2)
Amounts distributed by the Trust, as provided in paragraph 143.1(1.2)(d), include all amounts paid to or for the benefit of the Athlete … under the trust provisions. ...
Technical Interpretation - External summary
30 October 2014 External T.I. 2013-0500491E5 - Pension from XXXXXXXXXX -- summary under Subparagraph 110(1)(f)(i)
Before discussing the non-availability of a foreign tax credit (see summary under s. 126(1), CRA stated: [The] pension income received … is not subject to tax in a member state of the European Union, such as XX. ...
Technical Interpretation - External summary
12 June 2014 External T.I. 2014-0527651E5 - Whether keeping a zoo is a farming activity -- summary under Farming
. … Therefore, where a taxpayer raises or exhibits wild or exotic animals such as lions, tigers, apes, or elephants, these types of animals would not, in our view, be considered as livestock…. ...
Technical Interpretation - External summary
24 October 2012 External T.I. 2012-0443721E5 F - Compensation - vente d'un immeuble -- summary under Damages
. … [W]e do not believe that you paid damages for the purpose of earning income from a business or property. ...
Technical Interpretation - External summary
2 April 2014 External T.I. 2014-0521041E5 F - Application de 13(7.1) -- summary under Subsection 13(7.1)
. … [S]ubsection 13(7.1) should apply and that the cost of the manure pit could be reduced by the government assistance received so that an election under subsection 13(7.4) would not be required and the amount of government assistance received will not be included in the taxpayer's income in the year received (unless the amount of government assistance received exceeds the cost of the pit). ...
Technical Interpretation - External summary
18 October 2012 External T.I. 2012-0452131E5 F - CIE, établissement domestique autonome -- summary under Paragraph 118(1)(b.1)
Consequently … it is possible for spouses living in the same self-contained domestic establishment as their children to be able to claim separate CTCs for separate children. ...
Technical Interpretation - External summary
12 May 2014 External T.I. 2014-0517021E5 - 233.3 - Definition of Specified Foreign Property -- summary under Specified Foreign Property
. … However, the shares of Forco would be specified properties [sic] of Canco pursuant to paragraph (c) of the definition of specified property [in] subsection 233.3(1)…. ...
Technical Interpretation - External summary
7 November 2014 External T.I. 2014-0536261E5 F - Bien à usage personnel -- summary under Personal-Use Property
. … Plamondon …defined… "primarily" as "to a great or the greatest degree; for the most part, mainly" and "principal" as "the most important, the first among many. ...