Search - 2002年 抽纸品牌 质量排名

3 January 2002 External T.I. 2001-0067955- Application of 75(2) & 107(4.1) to a trust Unedited CRA Tags 75(2) 107(4.1) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CCRA. ... XXXXXXXXXX 2001-006795 Annemarie Humenuk Attention: XXXXXXXXXX January 3, 2002 Dear Sir: Re: Subsection 75(2) Following a Trust-to-Trust Transfer of Property This is in reply to your letter of January 12, 2001, concerning the attribution of income earned on property transferred to a trust from another trust in circumstances where subsection 75(2) applied to the income earned on the property when it was held by the first trust. ... Murphy Manager Trusts Section International & Trusts Division Income Tax Rulings Directorate Policy and Legislation Branch?? ...

22 January 2002 Internal T.I. 2001-0105567- FTC & SBD- PATRONAGE DIVIDEND Unedited CRA Tags 125(1) 135(7) 126(1) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CCRA. ... January 22, 2002 Toronto Center TSO HEADQUARTERS Business Enquiries L. Holloway Verification & Enforcement Division (613)- 957-2104 ATTENTION: Patricia Caron 2001-010556 Foreign Tax Credit and Small Business Deduction override This memorandum is in response to your faxed memorandum of October 12, 2001. ...

5 April 2002 External T.I. 2002-0127075- Trusts & loans to person related to spouse Unedited CRA Tags 70(6) 73(1) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CCRA. ... XXXXXXXXXX 2002-012707 Annemarie Humenuk April 5, 2002 Dear XXXXXXXXXX: Re: Loans Made by a Post-1971 Spousal or Common-law Partner Trust This is in reply to your letter of December 21, 2001, in which you ask whether a loan to any of the family members of the income beneficiary of a post-1971 spousal or common-law partner trust at a rate equal to that charged by a chartered bank to its best customers (the "prime rate") would taint the trust as a post-1971 spousal or common-law partner trust for the purposes of subsections 70(6) and 73(1) of the Income Tax Act. ...

15 February 2002 External T.I. 2002-0118755- CHILD SUPPORT ARREARS & INTEREST Unedited CRA Tags 56(1)(B) 60(B) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CCRA. ... Eisner, CA (613) 957-8953 February 15, 2002 Dear XXXXXXXXXX: Re: Child Support Arrears and Interest This is in reply to your letter dated January 16, 2002, concerning the above-noted subject. ...

25 February 2002 Internal T.I. 2002-0118117- PART 1.3- ADVANCES & HOLDBACKS Unedited CRA Tags 181.2(3) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... Reasons: See memo February 25, 2002 Income Tax Appeals Division Income Tax Rulings and Barry Hassar Interpretations Directorate Manager K. ... B. 957-8984 Attention: John Kinston 2002-011811 Part I.3 Issues This is in response to your memorandum of January 11, 2002 requesting our comments with respect to a number of referrals you had received regarding several outstanding Part I.3 issues. ...

4 June 2002 External T.I. 2002-0125715- SR & ED- RELATED TO A BUSINESS Unedited CRA Tags 37(1)(a)(i) 37(8)(b) 37(8)(c) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CCRA. ... XXXXXXXXXX 2002-012571 Shaun Harkin, CMA June 4, 2002 Dear XXXXXXXXXX: Re: Technical Interpretation Request: Scientific Research and Experimental Development ('SR&ED") This is in reply to your letter of February 18, 2002 wherein you ask for our comments in respect of the following hypothetical situation: Hypothetical Situation (i) A Canadian incorporated private company functions as a Contract Research Organization ("CRO") and under the terms of its agreement with arm's length third parties it provides a variety of services, only some of which qualify under the definition of SR&ED in subsection 248(1) of the Income Tax Act (the "Act"). ...

19 July 2002 Internal T.I. 2002-0129737- EMPLOYEE PROFIT SHARING PLAN- SR & ED Unedited CRA Tags 37(1)(a)(i) 248(1) 2900(9) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CCRA. ... July 19, 2002 SR&ED Directorate Income Tax Rulings Financial Legislative Directorate Application Section B.G. Dodd 957-8954 Attention: Connie Ng 2002-012973 Employee Profit Sharing Plan- Salaries or Wages We are writing in reply to your memorandum dated March 19, 2002. ...

31 July 2002 Internal T.I. 2002-0143137- EXPENSES & BENEFITS YACHTS Unedited CRA Tags 18(1)(1) 1102(1)(F) 15(1) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CCRA. ... July 31, 2002 Mr. Leonard Fornelli HEADQUARTERS Verification and Enforcement Division Randy Hewlett, B.Comm. Ottawa Tax Services Office 613-957-8973 2002-014313 Deductible Expenses and Shareholder Benefits- Yachts We are writing in response to your inquiry of May 29, 2002, regarding the above-noted issue. ...

5 June 2002 External T.I. 2002-0122665- Shareholder rights plans & Section 86.186.1 Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CCRA. ... At the time that we received your correspondence, we understood from XXXXXXXXXX (telephone conversation of February 20, 2002, XXXXXXXXXX/Erskine), that you did not expect a written response from us commenting on your submission, however, we understand that you have recently changed your mind (telephone conversation of May 2002, Biscaro/XXXXXXXXXX) and we are therefore responding accordingly. ... As was explained at the International Fiscal Association seminar in Toronto on May 13, 2002, the CCRA does not intend to establish an administrative position with respect to this issue. ...

5 July 2002 Internal T.I. 2002-0144257- 20(12) Deduction & Accrual Basis Income Unedited CRA Tags 126 (1) 126 (7) 20 (12) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CCRA. ... July 5, 2002 Ms. Sheila Barnard Eliza Erskine Individual Returns and Payments 952-1361 Processing Directorate 25 McArthur Road, 8th Floor, Tower C 2002-014425 Interaction Between the Foreign Tax Credit ("FTC") Calculated Under Subsection 126(1) of the Income Tax Act (the "Act") and the Deduction Available Under Subsection 20(12) of the Act (the "20(12) Deduction"), Where the Foreign-Source Income is Taxed in Canada on an Accrual Basis and Taxed in the Foreign Country on a Cash Basis We are writing in response to your email letters to us of May 27, 2002 (the "May Email Letter"), and June 6, 2002 (the "June Email Letter"), regarding the above-noted subject. We also acknowledge our telephone conversation with you of June 19, 2002 (Wilson/Barnard). ...