Search - 2002年 抽纸品牌 质量排名
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Technical Interpretation - Internal summary
2 May 2002 Internal T.I. 2002-0132877 F - DÉDUCTIBILITÉ DES INTÉRÊTS -- summary under Subparagraph 20(1)(c)(i)
2 May 2002 Internal T.I. 2002-0132877 F- DÉDUCTIBILITÉ DES INTÉRÊTS-- summary under Subparagraph 20(1)(c)(i) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c)- Subparagraph 20(1)(c)(i) interest on borrowed money to acquire common shares generally deductible Regarding the deductibility of interest on money borrowed to acquire common or preferred shares, the Directorate stated: [I]n general and unless there are exceptional circumstances, interest on money borrowed to acquire common shares is deductible, taking into account that the potential return to the shareholder may exceed the cost of borrowing. … [I]nterest on money borrowed and used to acquire common shares may not be deductible where there is no expectation of profit from the investment. For example, in a situation where a corporation has not paid a dividend since incorporation and the facts clearly indicate that it has no intention of doing so, there may be a good argument for concluding that there is no expectation of profit …. ... However, where the dividend rate is lower than the cost of borrowing, the Agency allows the interest paid on money borrowed to acquire these shares to be deductible to the extent of the dividends included in the borrower's income from the shares in the year, grossed up in the case of an individual …. ...
Technical Interpretation - External summary
2 October 2002 External T.I. 2002-0118815 F - DIABETE JUVENILE -- summary under Paragraph 118.3(1)(a.1)
2 October 2002 External T.I. 2002-0118815 F- DIABETE JUVENILE-- summary under Paragraph 118.3(1)(a.1) Summary Under Tax Topics- Income Tax Act- Section 118.3- Subsection 118.3(1)- Paragraph 118.3(1)(a.1) child with juvenile diabetes does not generate the infirm credit, including under para. ... Furthermore, although controlling blood sugar levels is important for a person with diabetes, the time spent on this activity is not … time spent administering treatment. ... That activity does not usually last an average of 14 hours a week …. ...
Technical Interpretation - External summary
6 November 2002 External T.I. 2002-0132395 F - Robot Class 10 Catégorie 10 -- summary under Paragraph 10(a)
6 November 2002 External T.I. 2002-0132395 F- Robot Class 10 Catégorie 10-- summary under Paragraph 10(a) Summary Under Tax Topics- Income Tax Regulations- Schedules- Schedule II- Class 10- Paragraph 10(a) cost of remote-controlled duct-inspecting robot to be allocated between Class 10(a) (“automotive equipment” – which is broadly construed) and Class 8(j) (“radiocommunication equipment”) A person carries on a business of inspecting and maintaining ventilation and sewer system ducts using 4-wheeled robots to inspect ducts. ... Consequently, it seems that … it would be necessary to allocate the cost of the robot borne by the taxpayer between depreciable property in Class 10 and depreciable property in Class 8 …. ...
Technical Interpretation - External summary
6 November 2002 External T.I. 2002-0132395 F - Robot Class 10 Catégorie 10 -- summary under Paragraph 8(j)
6 November 2002 External T.I. 2002-0132395 F- Robot Class 10 Catégorie 10-- summary under Paragraph 8(j) Summary Under Tax Topics- Income Tax Regulations- Schedules- Schedule II- Class 8- Paragraph 8(j) cost of remote-controlled duct-inspecting robot to be allocated between Class 10(a) (“automotive equipment”) and Class 8(j) (“radiocommunication equipment” – informed by IA meaning of “radiocommunication”) A person carries on a business of inspecting and maintaining ventilation and sewer system duct using 4-wheeled robots to inspect ducts. ... Consequently, it seems that … it would be necessary to allocate the cost of the robot borne by the taxpayer between depreciable property in Class 10 and depreciable property in Class 8 …. ...
Technical Interpretation - External summary
25 January 2002 External T.I. 2001-0114615 F - CONTRAT DE RENTE PRESCRITE ET FIDUCIE -- summary under Clause 304(1)(c)(iv)(B)
25 January 2002 External T.I. 2001-0114615 F- CONTRAT DE RENTE PRESCRITE ET FIDUCIE-- summary under Clause 304(1)(c)(iv)(B) Summary Under Tax Topics- Income Tax Regulations- Regulation 304- Subsection 304(1)- Paragraph 304(1)(c)- Subparagraph 304(1)(c)(iv)- Clause 304(1)(c)(iv)(B) requirement of fixed term where holder is a trust other than under s. 104(4)(a) In the course of a general discussion, CCRA stated: Clause 304(1)(c)(iv)(B) … has the effect of requiring that annuity payments be payable for a fixed term where the holder of the contract is a trust other than a trust described in paragraph 104(4)(a) …. ...
FCA (summary)
Commission Scolaire des Chênes v. Canada, [2002] GSTC 11, 2001 FCA 264 -- summary under Consideration
Canada, [2002] GSTC 11, 2001 FCA 264-- summary under Consideration Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Consideration provincial subsidy was paid only if busing services provided The appellant school boards paid GST charges of independent bus companies for their busing services, and were compensated with a Quebec government subsidy (which was not subject to GST due to provincial government immunity). ... That is why a direct link is required. … It is therefore apparent that the purpose of the subsidy is unequivocal and that the link with the supply in question is equally unequivocal; the service must be provided, failing which the subsidy may be cancelled. ...
Decision summary
Canada v. Libra Transport (BC) Ltd., [2001] GSTC 57, aff’d 2002 FCA 347 -- summary under Agency
., [2001] GSTC 57, aff’d 2002 FCA 347-- summary under Agency Summary Under Tax Topics- General Concepts- Agency trucker presumed not to be an unlicensed insurer The appellant (“Libra”) carried on a truck transport business at volumes which exceeded the capacity of its own four rigs, so that it contracted with over 20 subcontractors, who owned their own rigs and operated them under the Libra umbrella. ... Bowie J stated (at para. 13): [O]nly an insurance company licensed to do so may sell insurance, and only a provincial government may sell motor vehicle licences… Vanex Truck Service was distinguished (at para. 17) on the basis that: [W]hat Vanex supplied to the drivers was the right to drive their vehicles with the benefit of licences and insurance for which it had paid … [and] the Appellant does not appear to have advanced an argument based on agency in that case. ...
Technical Interpretation - Internal summary
9 August 2002 Internal T.I. 2002-0145817 F - TAUX DE DEDUCTION - PTPE - ANNEE 2000 -- summary under Paragraph 38(c)
9 August 2002 Internal T.I. 2002-0145817 F- TAUX DE DEDUCTION- PTPE- ANNEE 2000-- summary under Paragraph 38(c) Summary Under Tax Topics- Income Tax Act- Section 38- Paragraph 38(c) BIL realized under s. 50 at end of year (2000) so that ½ an ABIL An allowable business investment loss was recognized by an individual in an amount equal to ½ the business investment loss (BIL) realized by the individual in 2000 given that such loss arose from a deemed disposition pursuant to s. 50(1) which, therefore, was deemed to have occurred on December 31, 2000. ...
Technical Interpretation - External summary
20 December 2002 External T.I. 2002-0159365 F - REMUNERATION NON MONETAIRE -- summary under Paragraph 153(1)(a)
20 December 2002 External T.I. 2002-0159365 F- REMUNERATION NON MONETAIRE-- summary under Paragraph 153(1)(a) Summary Under Tax Topics- Income Tax Act- Section 153- Subsection 153(1)- Paragraph 153(1)(a) no source deduction or remittance obligations where all remuneration is non-monetary Regarding the applicability of source deductions to non-monetary remuneration, CCRA stated: [T]he CCRA will not require source deductions for income tax purposes if non-monetary remuneration is the only payment received by the employee, since there is then no amount from which the employer can deduct. … [T]herefore … a corporation that pays certain of its directors remuneration consisting solely of shares of the corporation would not be required to deduct source deductions on the value of this remuneration in shares. ...
Technical Interpretation - External summary
14 January 2002 External T.I. 2001-0114035 F - ECHANGE D'ACTIONS ET PARAGRAPHE 9001(2) -- summary under Paragraph 9001(2)(a)
14 January 2002 External T.I. 2001-0114035 F- ECHANGE D'ACTIONS ET PARAGRAPHE 9001(2)-- summary under Paragraph 9001(2)(a) Summary Under Tax Topics- Income Tax Regulations- Regulation 9001- Subsection 9001(2)- Paragraph 9001(2)(a) shares will remain prescribed shares if the corporation ceases to be a QSBC after one year CCRA stated: Paragraph 9001(2)(a) … provides that a share of the capital stock of a corporation is a prescribed property of a taxpayer if, immediately after the time at which the taxpayer acquired the share, the corporation was a qualified small business corporation, and the corporation continued to be a qualified small business corporation for one year after that time. If the corporation ceases to be a qualified small business corporation after the one-year period following the time at which the taxpayer acquired the share, we are of the view that the share will remain a prescribed property, within the meaning of subsection 9001(2) …. ...