Search - 2002年 抽纸品牌 质量排名

Facts The facts, as provided in your memorandum dated March 19, 2002, and the taxpayer's submissions forwarded to us on September 10, 2002, are as follows: (a) XXXXXXXXXX (the "Taxpayer") is a Canadian citizen who was born in Ontario and who was resident in Canada until XXXXXXXXXX. ... Along with your memorandum dated March 19, 2002, you provided copies of the following contracts, which were entered into between the Taxpayer and various XXXXXXXXXX entities:? ... It is also to be noted that in cases involving theatrical shows where performances were given in different places, both the U.S. and New Zealand, which Tax Conventions use the same concepts of "permanent establishment" and "fixed base" as that found in the Convention, denied that a permanent establishment existed (see technical interpretation # E 2000-0036167). ...

La valeur totale des avantages imposables a été établie comme suit: XXXX XXXX XXXX XXXX $ XXXX $ XXXX $ 8. ... En effet, le libellé des paragraphes 15(1) et 246(1) utilise respectivement les termes suivants: « la valeur de l'avantage qu'une société confère […] » et « la valeur de l'avantage qu'une personne confère […] ». ... Le Bulletin IT-160R3 qui a été publié le 19 février 1992, a été archivé au cours de l'année 2002 avec l'avis suivant: « Cette publication est archivée et est conservée à des fins historiques. ...

The Queen, 2002 DTC 2185 (TCC), support the current deductibility of the disputed merger costs under subsection 9(1) and the non-applicability of 18(1)(a) and (b). ... (in November 1996), Colin Energy (in November 2002), BJ Services Company (The successor to Nowsco Well Service Ltd) v. ... In BJ Services, Campbell's, T.C.J., decision on this issue is as follows, at page 2043: [38] [...] ...

Le XXXXXXXXXX (" Société 1 ") a émis une débenture échangeable à XXXXXXXXXX (le " détenteur ") pour un montant de XXXXXXXXXX $. ... (" Can-Am "), Snowball c. La Reine, 97 DTC 512 (C.C.I.) (" Snowball ")). 58. ... Qui plus est, dans une décision anticipée datée du XXXXXXXXXX 2002, la distinction entre l'application des sous-alinéa 20(1)f)(i) et (ii) était précisée (endnote 11). ...

As stated in the incoming, the following describes the duties of the Individual as a campus minister: "XXXXXXXXXX " The incoming further lists the following as some of the specific duties performed by the Individual: Preach and teach on spiritual and theological subjects. ... " We may consider the following jurisprudence in resolving the issue of 'congregation' and whether the Individual is considered to be 'teaching' the student group attending the campus ministry: In Shepherd v The Queen, 2002 DTC ("Shepherd"), the appellant was "a minister of the Conference" and it was acknowledged that the appellant met the status test. ...

23 July 2010 Internal T.I. 2010-0374761I7- Section 160 and Multiple Transfers of Property Unedited CRA Tags s. 152(3) & (8), 160 Principal Issues: Whether one assessment can be used to encompass a number of transfers of property. ... The Queen, [2000] 4 C.T.C. 2620 (T.C.C.), aff'd in [2002] 2 C.T.C. 75 (F.C.A.); Michaud v. ...

March 28, 2003 Summerside Tax Centre HEADQUARTERS E & A S.Parnanzone Mr. Calvin Waugh 957-2133 2002-017858 Technical Interpretation Request: Qualified Farm Property This is in reply to your round trip memorandum of December 5, 2002, regarding the above-noted subject. ...

Indeed, the wording of subsections 15(1) and 246(1) use, respectively, the following terms: “ […] a benefit is conferred by a corporation […], then the amount or value of the benefit […] “ and “ […] a person confers a benefit […], the amount of the benefit […] “. ... However, we are of the opinion that, because of the similar wording of subsections 246(1) “ […] a person confers a benefit […], the amount of the benefit […] “ and 15(1) “ […] a benefit is conferred by a corporation […], then the amount or value of the benefit […] “, we can make an analogy using subsection 246(1), paragraph 6(1)(a) and subsection 15(1). ... Bulletin IT-160R3, which was published on February 19, 1992, was archived in 2002 with the following notice: “This publication is archived and kept for historical purposes. ...

The Queen, 2002 DTC 3846; Colbert v. The Queen, 2004 DTC 3300; Mossman v. The Queen, 2002 DTC 3881, and Pieper v. The Queen, 2004 DTC 2818). Based on the facts described above, it is our opinion that the Subsequent Agreement in the present situation did not supersede the Initial Order, at least as far as the child support provisions are concerned. ... The Queen, 2004 DTC 3300, at page 3309, determining whether a child is a "child of the marriage" is not an easy task: "However, the issue of whether one remains 'a child of the marriage' in accordance with the Divorce Act can be a tricky issue to resolve and will- in most cases, barring consent- require a decision by a competent tribunal. [...] ...

It is also an agreed fact (see our Document # 2003-0018905, dated June 20, 2003), that the XXXXXXXXXX corporate business tax is an income or profit tax and therefore a "business-income tax" within the meaning assigned by subsection 126(7) of the Act. ... The most relevant ones are Documents # 2000-0001017 and Document #9235160. ... This is consistent with CRA's position as expressed in Documents # 2000-0001017 and #9235160. ...