Search - 阿里法拍 司法拍卖
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Technical Interpretation - Internal
27 November 2000 Internal T.I. 2000-0054097 - SALARY CONTINUANCE VS RETIRING ALLOWANCE
The Agreement states that the payments of this income were to include "all entitlements you may have under Company policy, common law, as well as any statutory entitlements to notice pay, severance pay, and vacation pay you may have under the Employment Standard Act ". 4. ...
Technical Interpretation - Internal
13 September 2001 Internal T.I. 2001-0083067 - HEALTH AND WELFARE TRUSTS
September 13, 2001 Toronto East TSO HEADQUARTERS Small/Med Business Audit Shaun Harkin, CMA Verification & Enforcement (613) 957-9229 Attention: Mike Bolton Trust and Pension Section 2001-008306 XXXXXXXXXX Health and Welfare Trust ("HWT") This is in reply to your memorandum dated May 4, 2001 in which you asked for our comments on the acceptability of the above named trust agreement, which accompanied your letter, as a HWT. ...
Technical Interpretation - Internal
9 July 2001 Internal T.I. 2000-0047617 - SOJOURNING
Principal Issues: Various issues on sojourning Position: see memo attached Reasons: see memo attached July 9, 2001 International Tax Directorate International Section Rene Fleming, Manager Tim Kuss Policies & Publications Section 957-2117 Policy and Programs Division Attention: Ved Arora 2000-004761 Paragraph 250(1)(a)- Sojourning in Canada You have requested our views with regard to certain issues raised by XXXXXXXXXX, regarding the applicability of paragraph 250(1)(a) to determine the residence status of certain airline pilots employed by a Canadian resident airline. ...
Technical Interpretation - Internal
17 May 2002 Internal T.I. 2002-0139547 - TRANSFER OF INCOME TO A CORP.
May 17, 2002 Audit Directorate HEADQUARTERS Anne Wilson Wayne Antle, CGA Manager (613) 957-2102 Technical Applications & Valuations Division 2002-013954 Transfer of Professional Income to a Corporation This is further to your email of May 8, 2002, concerning our decision not to revise our position on the transfer of professional income to a professional corporation, despite the decision of the Tax Court in the case of Jerome Wallsten and Lakeside Properties Ltd. v. ...
Technical Interpretation - Internal
14 June 2002 Internal T.I. 2001-0096897 - SUPPLEMENTARY EMPLOYEE RETIREMENT PLAN
& 2.) In our document 9619803 dated XXXXXXXXXX, 1996, which the taxpayer's representative has referred to, we provided rulings in respect of a supplemental retirement arrangement ("SRA") that was similar in design to the plan in question here. ...
Technical Interpretation - Internal
8 July 2002 Internal T.I. 2002-0141647 - SALE OF PROPERTY TO MORTGAGEE
July 8, 2002 XXXXXXXXXX Income Tax Rulings Verification & Enforcement Division Directorate XXXXXXXXXX Bob Naufal (613) 957-2744 2002-014164 XXXXXXXXXX This is in response to your memo dated May 14, 2002, wherein you requested our comments as to whether Pre-1994 Section 79 ("Former Section 79") or Section 80 ("Former Section 80") would apply to the above-mentioned Taxpayer. ...
Technical Interpretation - Internal
13 September 2002 Internal T.I. 2002-0124467 - RRSP AMOUNTS PAYABLE AFTER ANNUITANT DIES
MAIL TYPE: CCRA Documents; (Forms & Guides, Internal Queries, Appeals Referrals) Principal Issues: Can the estate claim a subsection 146(8.9) deduction on the final 146(1) return in respect of RRSP amounts still unclaimed by the beneficiary? ...
Technical Interpretation - Internal
27 February 2003 Internal T.I. 2001-0093047 - REGISTERED RETIREMENT SAVING PLAN
February 27, 2003 Individual Returns and Headquarters Payments Processing Directorate Income Tax Rulings Pensions & Trusts Section Directorate G. ...
Technical Interpretation - Internal
1 December 1999 Internal T.I. 9919237 F - RENTE VIAGERE-PENSION ALIMENTAIRE
Dans ce jugement, il est indiqué que le tribunal croit qu'il y a lieu de fixer la pension alimentaire dont Madame a besoin et que Monsieur pourrait lui payer à XXXXXXXXXX $ par mois. ...
Technical Interpretation - Internal
26 May 2000 Internal T.I. 1999-0009037 - Income Capital Gain Ireland Article VI
Troy of the North York Tax Services Office (file # 962478) concerning the same issue, such response will be amended to reflect our position described above. ...