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Miscellaneous severed letter
7 July 2009 Income Tax Severed Letter 2008-0300101R3 - Deductibility of interest
Early redemption ACO will have the right to redeem the Notes, in whole or in part, at a price equal to XXXXXXXXXX% of the principal amount of the Notes to be redeemed, plus accrued and unpaid interest to the date of redemption, by giving not less than XXXXXXXXXX and no more than XXXXXXXXXX days' prior notice on account of: • the termination of XXXXXXXXXX in respect of ACO's future obligations to pay the interest owing under the terms of the Initial Notes; • XXXXXXXXXX; any payment in respect of the Note becoming subject to additional amounts pursuant to a change of law, provided that no such notice of redemption shall be given earlier than XXXXXXXXXX days prior to the earliest date on which the ACO would be obliged to pay such additional amounts in relation to a payment in respect of Notes in accordance with the Indenture General redemption right The Notes shall be redeemable commencing XXXXXXXXXX and on each interest payment date thereafter, in whole or in part, at the option of ACO on not less than XXXXXXXXXX and not more than XXXXXXXXXX day's notice at a redemption price equal to XXXXXXXXXX% of the principal amount thereof, together in each case with accrued and unpaid interest to the date fixed for redemption. ...
Miscellaneous severed letter
7 May 1991 Income Tax Severed Letter - Detailed discussion of relocation and moving expenses
Paragraph 6(1)(a) & (b) The Act stipulates that, except for specific exemptions (usually group plans), benefits of any kind whatever received by an individual in respect of employment are to be included in income. ... The loss on the sale is calculated as the original purchase price + capital additions- net selling price; (7) interest costs on bridge financing in the purchase of the new residence, provided that all reasonable efforts are exercised to dispose of the old residence; (8) reasonable interim living expenses at the new location while awaiting occupancy of permanent accommodation at the new location; (9) legal fees and land transfer tax for the purchase of a new residence; (10) adjustments and alterations to furniture and fixtures from the old residence to accommodate them in the new residence, including plumbing and electrical changes in the new residence for this purpose; (11) connection and installation charges for utilities, appliances and fixtures which existed at the old residence; (12) automobile licence, inspection and drivers permit fees where such items were owned at the former location; (13) the cost of revision to a will necessitated by the move; (14) moving costs of personal items and household effects including automobile, boat or trailer; (15) the cost of house hunting trips to the new location including child and pet care expenses; (16) expenses for moving an employee and household out of a remote place after the work has been completed. ...
Miscellaneous severed letter
17 May 1990 Income Tax Severed Letter RRRR299 - Capital cost allowance of electrical generating equipment, steam generating equipment and cogeneration stations
Revenue Canada Contact Wehn taxpayers request the name of a contact at Revenue Canada you may inform them that: • Written inquiries should be forwarded to the Director-General Specialty Rulings Directorate Legislative and Intergovernmental Affairs Branch Revenue Canada Taxation 875 Heron Road Ottawa, Ontario K1A 0L8 • For telephone inquiries they may call the Group #23 telephone person (613) 957-2088. ...
Miscellaneous severed letter
7 March 1991 Income Tax Severed Letter - Clearance Certificate under Petroleum and Gas Revenue Tax Act
The first technical issue to be answered is whether the words "... assignee, liquidator, administrator, executor and other like person... ... Opinion # 5-7778, dated November 1, 1985 by C. Savage). b) From the foregoing it is clear that the Department and the courts are in agreement that any person assuming duties qua liquidator can be subject to the provisions of subsection 159(2) of the ITA and by inference, subsection 14(9) of the PGRTA. ...
Miscellaneous severed letter
7 October 1991 Income Tax Severed Letter - Landfill Site Acquisitions
.' " Further support of this line of reasoning is found in the reasons for judgement by Justice Pratte of the Federal Court of Appeal in The Minister of National Revenue v. ... Ltd., [[1974] C.T.C. 63] 76 DTC 6083, where he said at page 6083; "... ...
Miscellaneous severed letter
9 September 1986 Income Tax Severed Letter
Walker & Co. Ltd. v. I.R.C. [1920] 3 K.B. 648]. In more recent rulings, cap interest rates based on an effective overall yield to maturity of 13.5% per annum and a flat 12% per annum were accepted at the outset of the financings as reasonable limits. ... " [at p.6184] CURRENT POSITION AND OUTSTANDING ISSUES To date, to our knowledge, there have been no favourable rulings granted by the Department in respect of participation payments under paragraph 20(1)(e) of the Act. ...
Miscellaneous severed letter
26 May 1989 Income Tax Severed Letter 5-7327 - [890526]
Taylor wrote "... I do not agree with counsel for the respondent that only costs incurred while the automobile is in motion are qualified for deduction as travelling expenses.... ... During the course of the Commons debate on Bill C-139 (Commons Debates March 10, 1983 p. 23670) the Government was specifically asked to define operating costs to which the response was: "... this includes gasoline, repairs, insurance and other charges that would be applied against the vehicle to keep it on the road. ...
Miscellaneous severed letter
17 April 1989 Income Tax Severed Letter 7-3772 - [Interpretation Bulletin Project Number 1492 (Version 2)Revision of IT-441]
As per paragraph 2 of IT-172R "... where an individual has income from non-business (e.g., property held to earn investment income) he... is not subject to the above capital cost allowance restriction (i.e. ... Page 18 & 19- Capital Cost Allowance- Amount Claimable The Department of Finance uses the phrase "the half-year rule" rather than the "one-half year rule" used in the fifth line on page 18. ...
Miscellaneous severed letter
30 November 1991 Income Tax Severed Letter 4M04620 - Numerous Issues Covered
B 1 common share 1 common share FMV = $1,000 FMV = $1,000 OPCO In the above example, Opco issues another share to Mrs. ... Round Table- Federal Taxation system 33.25 Answer by the Department of Revenue The Department has appealed Fortin & Moreau to the Federal Court-Trial Division. ... However, the exception does not apply to buildings including a permanent R & D infrastructure. ...
Miscellaneous severed letter
7 July 1996 Income Tax Severed Letter 9608843 - Distress preferred shares
PRINCIPAL ISSUES: % ownership and amount being financed by DPS. POSITION: Give rulings. REASONS: Only % holding of debt being refinanced. XXXXXXXXXX XXXXXXXXXX 960884 XXXXXXXXXX Attention: XXXXXXXXXX XXXXXXXXXX, 1996 Dear Sirs: Re: XXXXXXXXXX We are writing in response to your letter dated XXXXXXXXXX wherein you requested an advance income ruling on behalf of the above-noted taxpayers. ...