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Technical Interpretation - External

8 February 2011 External T.I. 2011-0393431E5 - Overseas Employment Tax Credit

For more information about how to obtain an advance income tax ruling, please refer to Information Circular 70-6R5, "Advance Income Tax Ruling", dated May 17, 2002. ... Yours truly, for Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...
Technical Interpretation - External

22 October 2010 External T.I. 2010-0381741E5 - Cash Purchase Tickets

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. ... The term "inventory" is defined in subsection 248(1) of the Act to mean "... a description of property the cost or value of which is relevant in computing a taxpayer's income from a business for a taxation year or would have been so relevant if the income from the business had not been computed in accordance with the cash method... ...
Technical Interpretation - External

10 June 2010 External T.I. 2009-0328661E5 - Employees Profit Sharing Plan

The employer's contributions cannot exceed 6 % of the particular Member's salary for that calendar year, but have to be at least $100. ... 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. ...
Technical Interpretation - External

9 November 2010 External T.I. 2010-0379751E5 - Regulations 1100(1)(a.2) and 101(5b.1)

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. ... Yours truly, Sandy Parnanzone For Director Business and Partnerships Division Income Tax Rulings Directorate Legislative Policy & Regulatory Affairs Branch ...
Technical Interpretation - External

7 October 2010 External T.I. 2009-0344201E5 - Canada-US Tax Convention

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 a request for an advance income tax ruling submitted in the manner set out in Information Circular 70-6R5, Advanced Income Tax Rulings, dated May 17, 2002. ... Yours truly, for Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...
Technical Interpretation - External

10 March 2011 External T.I. 2010-0388771E5 - Joint venture versus partnership

Historically, the Club generates approximately XXXXXXXXXX % of its revenue from weddings, banquets and meetings, with the majority of the revenue generated from the golf course operations. ... 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. ...
Technical Interpretation - External

15 March 2011 External T.I. 2010-0376321E5 - Health and Welfare Trust

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 a request for an advance income tax ruling submitted in the manner set out in Information Circular 70-6R5, "Advanced Income Tax Rulings", dated May 17, 2002. ... For example, if the plan or arrangement is such that there is little risk that the employee will not eventually be reimbursed for the full amount allocated to that employee annually, then the arrangement is not a plan of insurance and therefore, not a private health services plan. [...] ...
Technical Interpretation - External

15 March 2011 External T.I. 2010-0391431E5 - Settlement - general damages

Our Comments Written confirmation of the tax implications inherent in particular transactions may only be 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. ... " On the basis of the Supreme Court of Canada's in Nowegijick, 83 DTC 5041, which opined that the words "in respect of" are "... of the widest possible scope," we have taken the position that a retiring allowance can encompass all types of payments arising from an employee's loss of employment. ...
Technical Interpretation - External

10 March 2011 External T.I. 2011-0395721E5 - Overseas Employment Tax Credit

For more information about how to obtain a ruling, please refer to Information Circular 70-6R5, "Advance Income Tax Ruling", dated May 17, 2002. ... Yours truly, for Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...
Technical Interpretation - External

11 August 2010 External T.I. 2010-0368681E5 - Ownership of a Principal Residence

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. ... Yours truly, Sandy Parnanzone For Director Business and Partnerships Division Income Tax Rulings Directorate Legislative Policy & Regulatory Affairs Branch ...

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