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Technical Interpretation - Internal
24 October 2011 Internal T.I. 2011-0404731I7 - XXXXXXXXXX -Paragraph 149(1)(l)
The funds for these expenses must come from "amounts contributed to the fund on behalf of the XXXXXXXXXX " (it is not clear to us what amount is paid on behalf of the XXXXXXXXXX and who is making this payment). ...
Technical Interpretation - Internal
22 March 2011 Internal T.I. 2011-0396221I7 - 45(2) Election - deemed no change in use
Yours truly, Sandy Parnanzone Manager, For Director Business and Partnerships Division Income Tax Rulings Directorate Legislative Policy & Regulatory Affairs Branch ...
Technical Interpretation - Internal
5 April 2011 Internal T.I. 2009-0342481I7 - Canada-France Tax Treaty, Article XX
Yours truly, Sherry Thomson for Director International Section I International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch FOOTNOTES Note to reader: Because of our system requirements, the footnotes contained in the original document are shown below instead: 1 We have attached an English translation of the terms of work for your reference. 2 Alternatively, in some situations, income paid to a student could be considered "a scholarship, fellowship or bursary" within the meaning of paragraph 56(1)(n) of the Act. ...
Technical Interpretation - Internal
13 October 2011 Internal T.I. 2011-0393101I7 - Transitional Tax Debit/Credit Calculation
13 October 2011 Internal T.I. 2011-0393101I7- Transitional Tax Debit/Credit Calculation Unedited CRA Tags Ss. 37(11) & 220(3.2), and Reg. 600 Principal Issues: Whether the election provided in variable "I" of the calculation of the "total federal balance" under subsection 48(4) of the Taxation Act, 2007 (Ontario) can be filed late or amended. ...
Technical Interpretation - Internal
2 June 2010 Internal T.I. 2010-0357921I7 - Replacement Property - Amalgamation
On XXXXXXXXXX, Subco 1 purchases XXXXXXXXXX % of the shares of an arm's length Canadian-controlled private corporation ("Subco 2"). 4. ...
Technical Interpretation - Internal
18 January 2011 Internal T.I. 2010-0390971I7 - Wind Turbines and ITCs
Under subsection 4600(2) of the Regulations, property is "prescribed machinery and equipment" if, inter alia, it is depreciable property of the taxpayer that is "... ...
Technical Interpretation - Internal
3 August 2010 Internal T.I. 2010-0369281I7 - Clergy residence deduction
It is our understanding that the mission of the Entity is "XXXXXXXXXX " In Zylstra Estate v The Queen, 94 DTC 6687, Mackay, J. made the following comments when concluding why The Ontario Bible College and Ontario Theological Seminary ("OBC") and the Institute of Christian Studies ("ICS") were not considered a religious order for the purpose of claiming a clergy residence deduction pursuant to paragraph 8(1)(c): "There are two principal considerations which lead me to conclude that neither OBC nor ICS is a "religious order" within the intention of paragraph 8(1)(c). ...
Technical Interpretation - Internal
20 April 2010 Internal T.I. 2010-0355231I7 - Clergy residence deduction
The Entity's work involves "XXXXXXXXXX ". Its mandate is "to bring hope to the hungry, hurting and homeless through showing the love of God through word and deed". ...
Technical Interpretation - Internal
2 April 2009 Internal T.I. 2008-0302631I7 - CCA Recapture and Cash Basis Taxpayer
The reasons given by the Taxpayer's wife in January 2009 for the conclusion by the Taxpayer that the debt became bad at the end of XXXXXXXXXX were as follows: (1) the Purchaser was the "XXXXXXXXXX " brother of the Taxpayer; (2) the Taxpayer did not want to cause distress or duress to his family, and especially his father; (3) mad cow disease was becoming a problem in Western Canada; and (4) the Taxpayer did not want to spend money on trying to collect at that point. ...
Technical Interpretation - Internal
8 April 2009 Internal T.I. 2009-0310621I7 - Clergy Residence Deduction
8 April 2009 Internal T.I. 2009-0310621I7- Clergy Residence Deduction Unedited CRA Tags 8(1)(c) Principal Issues: Is a rabbi, who is employed in XXXXXXXXXX, a Jewish school, considered to minister a congregation for the purpose of the deduction pursuant to paragraph 8(1)(c) of the Income tax Act (the "Act") Position: No Reasons: Giving lectures on religion and providing counselling service to a group of students is not considered to be "in charge of " or "ministering a congregation" for the purpose of deduction provided in paragraph 8(1)(c) of the Act April 8, 2009 XXXXXXXXXX TSO HEADQUARTERS Office Audit Section V. ...