Search - 2002年 抽纸品牌 质量排名

Our Comments Written confirmations of the tax implications inherent in particular transactions are provided by this Directorate where the transactions are proposed and are the subject matter of an advance income tax ruling submitted in the manner set out in Information Circular 70-6R5, Advance Income Tax Rulings, dated May 17, 2002. ... Yours truly, Fiona Harrison, CPA, CA Manager Resources Section Income Tax Rulings Directorate Legislative Policy & Regulatory Affairs Branch ...

OUR COMMENTS Written confirmation of the income tax implications inherent in particular transactions is given by this directorate only where the transactions are proposed and are the subject matter of an advance income tax ruling request as described in Information Circular 70-6R5 dated May 17, 2002 issued by the Canada Revenue Agency ("CRA"). ... Yours truly, Fiona Harrison, CPA, CA Manager, Resources Section Reorganizations Division Income Tax Rulings Directorate Legislative Policy & Regulatory Affairs Branch FOOTNOTES Note to reader: Because of our system requirements, the footnotes contained in the original document are shown below instead: 1 R.S.C. 1985, c. 1 (5th suppl.) as amended; hereinafter (the "Act"). ...

Our Comments Written confirmations of the tax implications inherent in particular transactions are provided by this Directorate where the transactions are proposed and are the subject matter of an advance income tax ruling submitted in the manner set out in Information Circular 70-6R5, Advance Income Tax Ruling, dated May 17, 2002. ... In paragraph 41 of IT-145R (Consolidated)- Canadian Manufacturing and Processing Profits – Reduced Rate of Corporate Tax (Cancelled), the CRA has indicated that, "The activities connected with the processing of film into prints and slides, negatives into prints and the enlarging of prints are considered to be qualified activities. ...

Our Comments Written confirmation of the tax implications inherent in actual proposed transactions is given by this Directorate only where the transactions are the subject of an advance income tax ruling request submitted in the manner set out in Information Circular 70-6R5, entitled ‘Advance Income Tax Rulings’, dated May 17, 2002. ... Your concern appears to be with respect to our response to question # 12 at the 2011 STEP conference wherein the discussion was about the reporting by a Canadian investor of a distribution from a foreign mutual fund that arose from capital gains realized by the fund. ...

2 November 2012 External T.I. 2012-0438961E5- RRIF payment to a non-resident CRA Tags Income Tax Conventions Interpretation Act – Section 5. 146.3(1) Convention between the Government of Canada and the Government of the United Mexican States- Article 17 212(1)(q) Principal Issues: Withholding tax applicable to a RRIF payment to a non-resident. ... Written confirmation of the tax implications inherent in actual proposed transactions is given by this Directorate only where the transactions are the subject of an advance income tax ruling request submitted in the manner set out in Information Circular 70-6R5, Advance Income Tax Rulings, dated May 17, 2002. ...

Position: General comments only – but the particular shares may not qualify. ... Our Comments Written confirmations of the tax implications inherent in particular transactions are provided by this Directorate where the transactions are proposed and are the subject matter of an advance income tax ruling submitted in the manner set out in Information Circular 70-6R5, “Advance Income Tax Ruling”, dated May 17, 2002. ...

Our Comments: Written confirmation of the tax implications inherent in particular transactions is given by this Directorate only where the transactions are proposed and are the subject matter of an advance income tax ruling request submitted in the manner set out in Information Circular 70-6R5, Advance Income Tax Rulings, dated May 17, 2002. ... Amount for an eligible dependant (wholly dependent person credit / eligible dependent tax credit) Where in a taxation year parents live separate and apart, have shared custody of a minor child who resides with each parent approximately 50% of the time, and each parent is required to make support payments for the child and otherwise meets the criteria set out in paragraph 118(1)(b) of the Income Tax Act ("Act"), subsection 118(5.1) of the Act effectively allows either parent to claim the amount for an eligible dependant under paragraph 118(1)(b) for the child in the taxation year. ...

Written confirmation of the tax implications inherent in particular transactions is given by this Directorate only where the transactions are proposed and are the subject matter of an advance income tax ruling request submitted in the manner set out in Information Circular 70-6R5, Advance Income Tax Rulings, dated May 17, 2002. ... The disposition of a leasehold interest is discussed in Interpretation Bulletin IT-464R, Capital Cost Allowance – Leasehold Interests. ...

Written confirmation of the tax implications inherent in particular transactions is given by this Directorate only where the transactions are proposed and are the subject matter of an advance income tax ruling request submitted in the manner set out in Information Circular 70-6R5, Advance Income Tax Rulings, dated May 17, 2002. ... The Supreme Court's comments in Ludco (2001 SCC 62) are discussed in paragraph 10 of Interpretation Bulletin IT-533 Interest Deductibility and Related Issues: The interpretation of the term income was addressed in Ludco as follows: “…it is clear that ‘income’ in s. 20(1)(c)(i) refers to income generally, that is an amount that would come into income for taxation purposes, not just net income.” The court also said, “The plain meaning of s. 20(1)(c)(i) does not support an interpretation of ‘income’ as the equivalent of ‘profit’ or ‘net income’ …. ...

Our Comments Written confirmations of the tax implications inherent in particular transactions are provided by this Directorate where the transactions are proposed and are the subject matter of an advance income tax ruling submitted in the manner set out in Information Circular 70-6R5, “Advance Income Tax Ruling”, dated May 17, 2002. ... Subsection 70(10) of the Act defines a “share of the capital stock of a family farm corporation” (“the subsection 70(10) definition”) of a person at a particular time to mean a share of the capital stock of a corporation owned by the person at that time where, at that time, all or substantially all (i.e., generally 90% or more) of the fair market value of the property owned by the corporation was attributable to": (a) property that has been used by (i) the corporation or any other corporation, a share of the capital stock of which was a share of the capital stock of a family farm corporation of the person or of a spouse, common-law partner, child or parent of the person, (i.1) a corporation controlled by a corporation referred to in subparagraph (i), (ii) the person, (iii) the spouse, common law partner, child or parent of the person, … principally in the course of carrying on a farming business in Canada in which the person or a spouse, common-law partner, child or parent of the person was actively engaged on a regular and continuous basis (or, in the case of property used in the operation of a woodlot, was engaged to the extent required by a prescribed forest management plan in respect of that woodlot), (b) shares of the capital stock or indebtedness of one or more corporations all or substantially all of the fair market value of the property of which was attributable to property described in paragraph (c), or (c) properties described in paragraph (a) or (b).” ...