Search - 2002年 抽纸品牌 质量排名

Minor change in facts re ruling 2002-014913: The phrase "... minus the amount of benefits paid from the Registered Pension Plan" in paragraph 10 of the ruling was removed. 2. ... Reasonable under circumstances XXXXXXXXXX 2002-017671 XXXXXXXXXX, 2003 Dear XXXXXXXXXX: Re: XXXXXXXXXX (the "Organization") Advance Income Tax Ruling 2002-014913, dated XXXXXXXXXX, 2002 This is in reply to your letter of XXXXXXXXXX and several telephone calls (XXXXXXXXXX) in which you advise us of a minor change to paragraph 10 of the facts contained in the above Advance Income Tax Ruling. You indicated that the phrase "... minus the amount of benefits paid from the Registered Pension Plan" should be removed. ...

In Paragraph 16, the table and the immediately following paragraph are replaced with the following: Asset FMV Dco common shares XXXXXXof the FMV of the Dco shares and advances held by Aco Bco common shares $ XXXXXXXXXX Cco preferred shares $ XXXXXXXXXX XXXXXXXXXX $XXXXXXXXXX XXXXXXXXXX $ XXXXXXXXXX Net current assets XXXXXXXXXX of the FMV For greater certainty, XXXXXXXXXX will be classified as cash or near-cash property for the purposes of this distribution since an agreement has been reached for the sale of this property with a closing date of XXXXXXXXXX. 2. ... We confirm that the amendments enumerated above will not otherwise affect the rulings given in the Ruling and that, subject to the conditions set out therein, they will continue to be binding on the Canada Customs and Revenue Agency in accordance with the practice outlined in Information Circular 70-6R5 dated May 17, 2002. ...

PRINCIPAL ISSUES: Change in facts to Ruling 2005-015884 []. POSITION: Accepted. ... —Change in Facts to Advance Income Tax Ruling #2005-015884 [] (the “Ruling”) This is in reply to your facsimile letter of XXXXXXXXXX wherein you requested certain amendments to the Ruling that was issued to the above-noted taxpayers on XXXXXXXXXX, 2006. ... Notwithstanding the above, in accordance with the practice outlined in Information Circular 70-6R5, dated May 17, 2002, we confirm that subject to the conditions and time limit set out in the Ruling, the Ruling, as amended by the above, will continue to be binding on the Canada Revenue Agency as described therein. ...

XXXXXXXXXX 2003-001988 XXXXXXXXXX, 2003 Dear XXXXXXXXXX: Re: XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX Supplementary Advance Income Tax Ruling This is in reply to your letter of XXXXXXXXXX and is supplemental to our advance income tax ruling # 2003-000724 dated XXXXXXXXXX, 2003 (the "Ruling"). ... Amendment to the proviso to the Ruling The reference to paragraph 12 in the second last proviso should be a reference to paragraph 13, therefore that proviso is deleted and replaced with the following: "The above rulings are given subject to the general limitations and qualifications set out in Information Circular 70-6R5 issued on May 17, 2002, and are binding provided that LP C is wound-up as described in paragraph 13 above on or before XXXXXXXXXX and LP D is wound-up on or before XXXXXXXXXX." Notwithstanding the above-noted changes, in accordance with the practice outlined in Information Circular 70-6R5, dated May 17, 2002, we confirm that subject to the conditions and time limit set out in the Ruling, the rulings given in the Ruling, as amended by the above, will continue to be binding on the Canada Customs and Revenue Agency. ...

—Change in Facts to Advance Income Tax Ruling #2006-018810 [] (the “Ruling”) This is in reply to your request for a minor amendment to the Ruling that was issued to the above-noted taxpayer on XXXXXXXXXX, 2006. ... Notwithstanding the above, in accordance with the practice outlined in Information Circular 70-6R5, dated May 17, 2002, we confirm that subject to the conditions and time limit set out in the Ruling, the Ruling, as amended by the above, will continue to be binding on the Canada Revenue Agency as described therein. ...

In your letter, you outlined this scenario: • A for-profit corporation (“ACo”), registered in Alberta, is licensed to operate a 24-hour a day care facility for handicapped adults. • ACo is owned 50% each by Mrs. ... C. • The principal residence of Mrs. B is used to provide the 24-hour care and is considered to be the principal place of residence of the handicapped adults. • Mrs. ... 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. ...

PRINCIPAL ISSUES: Change in facts to Ruling 2005-016295 []. POSITION: Accepted. ... XXXXXXXXXX 2006-021258 XXXXXXXXXX, 2006 Dear XXXXXXXXXX: Subject: XXXXXXXXXX—Change in Facts to Advance Income Tax Ruling #2005-016295 [] (the “Ruling”) This is in reply to your facsimile of XXXXXXXXXX wherein you requested certain amendments to the Ruling that was issued to the above-noted taxpayer on XXXXXXXXXX. ... Notwithstanding the above, in accordance with the practice outlined in Information Circular 70-6R5, dated May 17, 2002, we confirm that subject to the conditions and time limit set out in the Ruling, the Ruling, as amended by the above, will continue to be binding on the Canada Revenue Agency as described therein. ...

., 2002 DTC 7395 (FCA), one may argue that dyke construction costs should always be characterized as current expenses or Canadian exploration expenses. ... Ltd., supra, at p. 648, reminds us that the classification of such expenditures '... depends on what the expenditure is calculated to effect from a practical and business point of view rather than upon the juristic classification of legal rights...', supra. ... " (See also the cases of Denison Mines Limited, 74 DTC 6525 (SCC), and Suncor Energy Inc., 2002 DTC 7395 (FCA).) 7. ...

Thomson (613) 957-2122 Attention: Joe MacDonald Technical Resource Officer 2002-013563 Payment from XXXXXXXXXX This is in reply to your memo to us on April 15, 2002, on behalf of XXXXXXXXXX letter was sent to you by the XXXXXXXXXX TSO. ... We would tend to agree with this characterization, based on the information we have been able to obtain.The courts have said that damages must be considered in light of the purpose and the effect of the action in which they were awarded (). ... Yours truly, Olli Laurikainen Section Manager for Division Director International & Trusts Division Income Tax Rulings Directorate Policy and Legislation Branch ...

PRINCIPAL ISSUES: Clarifying position taken in 2010-036838 [] with the following: a) Can each parent claim a child under line 305 as an equivalent-to-spouse, where there is a “set off” child support payment? ... Robertson, CMA April 27, 2011 Dear XXXXXXXXXX: Re: Eligible Dependent Credit (EDC), [formerly known as Equivalent-to-Spouse Credit]- Child Support Payments with “Set off” This letter clarifies issues addressed in our file 2010-036838 []. ... 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, (IC 70-6R5) dated May 17, 2002. ...