Search - 2002年 抽纸品牌 质量排名

To make such a request the advance income tax ruling must be submitted in accordance with the guidelines set out in Information Circular 70-6R5 ("IC-70-6R5") dated May 17, 2002. ... Kruco Inc., 2003 DTC 5506, which was described as follows: "... an amount will generally only be included in a corporation's safe income to the extent that it has been included in the determination of its net income for tax purposes or is an adjustment specifically set out in paragraph 55(5)(b) or (c). ...

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. ... As described in paragraph 12(1)(x), these amounts include those that "... can reasonably be considered to have been received (iii) as an inducement, whether as a grant, subsidy, forgivable loan, deduction from tax, allowance or any other form of inducement, or (iv) as a refund, reimbursement, contribution or allowance or as assistance, whether as a grant, subsidy, forgivable loan, deduction from tax, allowance or any other form of assistance, in respect of (A) an amount included in, or deducted as, the cost of property, or (B) of an outlay or expense". ...

14 June 2005 External T.I. 2004-0086631E5- royalty-reproduction distribution Unedited CRA Tags 212(1)(d)(vi) Article VII & par. 3(a) of Article XII of the Canada-US Income Tax Convention Principal Issues: Whether a royalty payment based on the net sales of reproduced artwork is a "royalty or similar payment on or in respect of a copyright in respect of the production or reproduction of any literary, dramatic, musical or artistic work" within the meaning of subparagraph 212(1)(d)(vi) of the Act and is therefore exempt from Part XIII withholding tax otherwise payable under paragraph 212(1)(d). ... 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 IC 70-6R5 dated May 17, 2002 issued by the Canada Revenue Agency ("CRA"). ...

Written confirmation of the tax implications inherent in particular transactions can be provided by this Directorate 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, Advanced Income Tax Rulings, dated May 17, 2002. ... Murphy Section Manager for Division Director International & Trusts Division Income Tax Rulings Directorate Policy and Planning Branch ...

Even though the individual has received his Permanent Resident Card issued by the Immigration & Naturalization Service of the U.S., he has not relocated his home to the U.S. ... We note that written confirmation of the income tax implications arising out of a particular fact situation are given by this Directorate only where the circumstances or events are the subject matter of an advance income tax ruling request as described in Information Circular IC 70-6R5 dated May 17, 2002 issued by the CRA. ...

" La définition de "revenu" au paragraphe 129(4), prévoit que le " revenu d'une société pour une année d'imposition tiré d'une source qui est un bien: a) comprend le revenu tiré d'une "entreprise de placement déterminée" (au sens de la définition prévue au paragraphe 125(7)) qu'elle exploite au Canada, sauf celui tiré d'une source à l'étranger; b) ne comprend pas le revenu tiré d'un bien qui, selon le cas: (i) se rapporte directement ou accessoirement à une entreprise quelle exploite activement; (ii) est utilisé ou détenu principalement pour tirer un revenu d'une entreprise qu'elle exploite activement. ... Nous vous soulignons que la présente opinion ne constitue pas une décision anticipée et, tel que mentionné au paragraphe 22 de la Circulaire d'information 70-6R5 du 17 mai 2002, elle ne lie pas l'ARC à l'égard d'une situation factuelle particulière. ...

See # 56309, 9430695, 9702488, 9335805, 9326897, 9201395, 51672, 940972. ... This amendment applies to gifts made after February 18, 1997, and before 2002. ...

In your letter, you state that you care for mentally and / or physically disabled children and adults in your home. ... 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 ruling request submitted in the manner set out in Information Circular 70-6R5, Advance Income Tax Rulings, dated May 17, 2002. ...

., states as follows: "--- I would add only this: the Income Tax Act, read as a whole, envisages that a distribution of corporate surplus to shareholders is to be taxed as a payment of dividends. ... The above comments are an expression of opinion and, as noted in Information Circular 70-6R5 issued on May 12, 2002, are not binding on the Canada Customs and Revenue Agency. ...

This condition is subject to the draft legislation released by the Department of Finance in December, 2002, which proposes to permit the recognition of a gift, for tax purposes, in some circumstances where the donor receives consideration or a benefit for the transfer of property. ... Reference may be had to CCRA Interpretation Bulletin IT-226R, "Gift to a Charity of a Residual Interest in Real Property or an Equitable Interest in a Trust " in this respect, which is available on the CCRA website at http://www.ccra-adrc.gc.ca/E/pub/tp/it226r/it226r-e.html. ...