Search - 2005年 抽纸品牌 质量排名

19 May 2005 External T.I. 2004-0072331E5- Whether 17(2) applies Unedited CRA Tags 17(2) 17(15) exempt loan or transfer Principal Issues: Whether 17(2) applies in the situation described Position: Probably Reasons: Request must be resubmitted as a request for an advance income tax ruling, but on its face, it appears that the scenario meets the conditions in 17(2). ... Thomson May 19, 2005 Dear XXXXXXXXXX: Re: Application of subsection 17(2) This is in reply to your letter of April 20, 2004 regarding the application of subsection 17(2) of the Income Tax Act (the "Act") to the scenario described below. ... Yours truly, Olli Laurikainen, C.A., Manager for Director International & Trusts Division Income Tax Rulings Directorate ...

11 May 2005 Roundtable, 2005-0118731C6 F- Contrat avec une société d'affacturage Unedited CRA Tags 181.2(3) Principales Questions: Un montant dû à une société d'affacturage peut-il être inclus dans le calcul du capital en vertu de l'alinéa 181.2(3) de la L.I.R.? ... TABLE RONDE SUR LA TAXE SUR LE CAPITAL APFF- COLLOQUE FISCALITÉ INTERPROVINCIALE & TAXE SUR LE CAPITAL Question 2 Poste au passif résultant de transactions avec une société d'affacturage La société A obtient un financement d'une société d'affacturage. ... Roy 2005-011873 Les 11 et 12 mai 2005 ...

23 June 2005 External T.I. 2005-0127911E5- residence of a trust Unedited CRA Tags 104 Principal Issues: Will Canada recognize a trust as a resident of the US if it is considered resident in the US for US tax purposes? ... XXXXXXXXXX 2005-012791 Annemarie Humenuk Attention: XXXXXXXXXX June 23, 2005 Dear Sirs: Re: Residence of a Trust This is in reply to your letter of December 3, 2004 in which you seek assistance in determining whether a particular unidentified trust is considered resident in Canada for the purposes of the Income Tax Act, R.S.C. 1985 (5th supp.) c. 1, as amended (the "Act"). ... Murphy Section Manager for Division Director International & Trusts Division Income Tax Rulings Directorate Policy and Planning Branch ...

5 January 2005 External T.I. 2004-0083551E5- Immigration of a discretionary trust Unedited CRA Tags 94(1)(c) 128.1(1) 115(1) 104(2) Principal Issues: Follow up comments on the answer we provided to question 7 of the 2004 STEP Round table. ... XXXXXXXXXX 2004-008355 Éric Allard-Pouliot January 5, 2005 Dear Sir: Re: Technical Interpretation Request: 2004 STEP Round Table- Question 7 This is in reply to your electronic mail of June 30, 2004, regarding the above-noted subject. ... Alain Godin Section Manager For Division Director International & Trusts Division Income Tax Rulings Directorate Policy and Planning Branch ...

2005 Ruling 2005-0139661R3- Withholding Index-Linked Notes Unedited CRA Tags 212(1)(b)(iii)(D) 9 Principal Issues: Is the positive return of a foreign denominated index-linked note exempt from withholding under 212(1)(b)(iii)(D) Position: YES Reasons: Not linked to performance of the payor XXXXXXXXXX 2005-013966 XXXXXXXXXX, 2005 Dear XXXXXXXXXX: Re: Advance Income Tax Ruling XXXXXXXXXX This is in reply to your letter of XXXXXXXXXX, wherein you request an advance income tax ruling on behalf of the above named taxpayer. ... C. 1985(5th Supp.) c.1, as amended to the date hereof; (b) "A Co" means XXXXXXXXXX and is further described in paragraphs 1 to 3; (c) "CRA" means the Canada Revenue Agency; (d) "Final Index Value" means the value of the Index on the third business day prior to the Maturity Date of the Note; (e) "Index" means the XXXXXXXXXX; (f) "Index Return" means the positive amount, if any, that would be added to the Principal Amount and is calculated based on the change in the value of the Index between the Initial Index Value and Final Index Value as described in paragraph 8(b); (g) "Issue Date" means the date a Depositor advances an amount to A Co and the Notes are issued; (h) "Initial Index Value " means the value of the Index on the Issue Date of the Note; (i) "Maturity Date" means a date that is a stipulated date between XXXXXXXXXX and XXXXXXXXXX years after the Issue Date, upon which date the note would mature; (j) " Notes" means the Notes to be issued pursuant to the XXXXXXXXXX program and further described in paragraphs 6 and 7; (k) "OSFI" means the Office of the Superintendent of Financial Institutions; (l) "Regulations" means the Income Tax Regulations; and (m) "XXXXXXXXXX" means a fund-raising program which involves the issuance of debt obligations XXXXXXXXXX residents pursuant to a shelf prospectus, prospectus supplement and various terms supplements filed with XXXXXXXXXX; Statement of Facts 1. ...

These Proposed Amendments were subsequently promulgated on August 31, 2005. ... It is anticipated that the first XXXXXXXXXX Test Turbines (# XXXXXXXXXX) will be commissioned and enter into service in XXXXXXXXXX. The last XXXXXXXXXX Test Turbines (# XXXXXXXXXX) will be commissioned and enter into service in XXXXXXXXXX, after which, if the testing phase is successful, it is planned that XXXXXXXXXX additional wind turbines will be installed. ...

Your initial intention back in 2003 (when you made the down payment) was to take up residence in the condo unit as soon as you acquired it in 2005. ... Among other things, the definition in Section 54 says that the "principal residence of a taxpayer for a taxation year means a particular property that is a housing unit [...] that is owned, whether jointly with another person or otherwise, in the year by the taxpayer, (a) where the taxpayer is an individual [...] if the housing unit was ordinarily inhabited in the year by the taxpayer or the taxpayer's spouse or common-law partner, former spouse or common-law partner or by a child of the taxpayer" [Emphasis ours]. ... While we regret that the election under subsection 45(2) would not be available to you in the scenario you describe in your letter of April 14, 2005, we trust our comments are of assistance to you. ...

Raisons: (1) Question de fait (2) Règles d'évaluation TABLE RONDE SUR LES PRODUITS FINANCIERS APFF- CONGRÈS 2005 QUESTION 12 Actions d'assurance vie. ... Réponse préparée en collaboration de la Division des applications techniques et des évaluations Direction générale des programmes d'observation Sous la supervision de Sylvie Labarre pour la situation A 957-8981 Michel Lambert Le 7 octobre 2005 2005-013811 & 2005-013836 957-8962 TABLE RONDE SUR LES PRODUITS FINANCIERS APFF- CONGRÈS 2005 QUESTION 12 Life Insurance Shares A shareholder wants the proceeds of an insurance policy on his life, held by a corporation of which he is the sole shareholder, be paid to one person in particular, for example a former spouse. ... Answer prepared with the collaboration of the Technical Applications and Valuations Division Compliance Programs Branch Under the supervision of Sylvie Labarre for situation A 957-8981 Michel Lambert Otober 7, 2005 2005-013811 & 2005-013836 957-8962 ...