Search - 阿里拍卖 司法拍卖

. …. If, in the case described, there in fact is an allocation of capital gains of the SEC to its partners, we believe it would be difficult to maintain that they do not retain their character in the hands of the latter, including the Limited Partner.... ...

. … [G]eographic coherence [also] is required under the Treaty. ...

Rockies Corp, 2005 DTC 289) that "a corporation may opt for whichever instalment method under paragraph 157(1)(a) that it wishes, regardless of the instalment method that is deemed by subsection 161(4.1) to have been used for purposes of computing the corporation's interest in respect of unpaid or late instalments," CRA stated that "a corporation's functional currency election…does not hinder its ability to choose…[an] instalment method under paragraph 157(1)(a)," stated that it "will not consider the use of either the First Instalment Base Method or the Second Instalment Base Method where a reporter's Total EFC Instalments [the total required instalments, as converted to the EFC] using the respective instalment method exceed the reporter's EFC Taxes Payable for the year," and that it was appropriate "that each assessment of the CAD Taxes Payable of a functional currency reporter…[use] the instalment method that gives rise to the least amount of CAD Taxes Payable" – so that when re-determining the CAD Taxes Payable for a particular taxation year as a result of a s. 111(1)(a) deduction of a subsequent year's loss, the same instalment method that was originally used for the particular year is not required to be used to recalculate the CAD Taxes Payable. ...

. … Paragraph XXIX-A(3)…[inter alia requires:] …The item of income is derived from the source state (Canada) in connection with or incidental to that (US) trade or business (including any such income derived directly or indirectly by that resident person (US person) through one or more other persons that are residents of the source state (Canada)) ("Connected Test") …[I]nterest paid or credited by a Canadian resident to a US person might be considered "derived in connection with" a US active business in the following circumstances: the interest is paid or credited in respect of an account payable issued by [sic] the US person in the course of carrying on its US active business, the interest payments are in respect of borrowed money used for the purpose of earning income from a business carried on in Canada that is upstream, downstream or parallel to the US active business ("Canadian-Connected Business"), or the interest payments are funded out of the cash flow from such a Canadian-Connected Business. ...

. … [I]ncluding the value of an intercompany receivable balance pertaining to a loan made upstream as a distinct asset when determining the FMV of the wholly-owned lending subsidiary’s assets would result in the double counting… because when carrying out the gross asset value test for the parent corporation the value of the related intercompany payable balance is…ignored while the funds the parent received from the upstream loan would be included as a distinct asset of the parent…. ...

B ….. If there were three children, either Ms. A or Mr. B could claim the credit under paragraph 118(1)(b.1) in respect of the third child. ...

. … These corporate documents are not bilateral contracts…. Shares may or may not carry votes, but in respect of the governance of the corporation, typically only shareholders may vote on matters such as the election of the board of directors. ...