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10 October 2024 APFF Financial Strategies & Instruments Roundtable

Miscellaneous correspondence
Where the CCPC claims a foreign tax deduction under subsection 126(1) ("FTD"), a reduction is provided for in the description of B of the formula “A B” in subparagraph (a)(i) of the definition of NERDTOH. More specifically, the reduction is equal to the amount by which the CCPC's deduction for the year under subsection 126(1) (the “FTD”) in respect of its foreign non-business income (clause (A) of element B of the “A B” formula) exceeds 8% of the foreign investment income ("FII") (clause (B) of element B of the “A B” formula). ... This notional calculation of 8% of FII in clause (B) of element B of the “A B” formula applies regardless of whether a foreign country has levied a tax on foreign source income. ...

29 May 2018 STEP Roundtable - Official Response

Miscellaneous correspondence
Expressed mathematically, the following must be true for the condition to be met: (Services Income) < 0.9(Business Income) If both Services Income and Business Income equal zero, that statement is not true. ... Clarification with regard to the CRA’s views with regard to the application of subsection 70(5) to anon-resident taxpayer was provided in published external technical interpretation 2002- 0133410. ... Again, any interest and penalties calculated by virtue of Division | will be assessed for the relevant taxation years. ...