Search - 2005年 抽纸品牌 质量排名

2005 Ruling 2005-0126121R3- Supplemental ruling Unedited CRA Tags 20(1)(c) Principal Issues: Changes to ruling Position: Ruling modified Reasons: Changes do not affect validity of rulings given. XXXXXXXXXX 2005-012612 XXXXXXXXXX, 2005 Dear Sir: Re: Advance Income Tax Ruling 2004-007098 dated XXXXXXXXXX, 2005 ("the Ruling") XXXXXXXXXX This is in reply to your letters of XXXXXXXXXX requesting certain changes to the Ruling. ... Add the following Paragraphs following Paragraph 38: 38.1 Opco will borrow from an arm's-length lender or lenders an amount of money that will not exceed the amount of Opco's Adjusted Equity at that time. 38.2 Opco will use the money borrowed, as described in Paragraph 38.1, to effect a return of capital and the payment of a dividend to AcquisitionCo. 38.3 Acquisitionco will use the money received from Opco, as described in Paragraph 38.2, to repay to the Trust a portion of the principal amount outstanding in respect of the Trust Notes. 38.4 The Trust will then advance the money received from Acquisitionco, as described in Paragraph 38.3, to Opco in consideration for promissory notes of Opco (the " Trust Notes, Series One") having a principal amount equal to the amount of money advanced and having terms and conditions that are otherwise identical to those of the Trust Notes. 38.5 Opco will use the money advanced to it by the Trust, as described in Paragraph 38.4, to repay the indebtedness to the lender or lenders described in Paragraph 38.1. ...

18 July 2005 Internal T.I. 2005-0130351I7- Automobile Operating Expense Benefit Unedited CRA Tags 6(1) 8(1)(h.1) Principal Issues: Can employee deduct the cost of motor vehicle operating costs if the vehicle is used for business purposes. Position: Question of Fact Reasons: General Information provided 2005-013035 (see 2005-013369) From: Majerus, Luisa Sent: July 18, 2005 2:32 PM To: Goyette, Brenda Subject: Answers to your questions Hi Brenda, RE: Automobile Operating Expenses and Alterations to a Recreational Vehicle ("RV") This is in reply to your two email requests dated May 12 and May 31, 2005. ... Majerus, CA Senior Rulings Officer Income Tax Rulings Directorate Policy & Planning Branch Canada Revenue Agency (613) 832-3488 ...

18 July 2005 Internal T.I. 2005-0133691I7- Modifying an RV for accessibility Unedited CRA Tags 118.2(2) Principal Issues: Does the cost of modifying an RV to make it wheelchair accessible qualify as a medical expense? Position: Question of Fact Reasons: General information provided 2005-013369 (see 2005-013035) From: Majerus, Luisa Sent: July 18, 2005 2:32 PM To: Goyette, Brenda Subject: Answers to your questions Hi Brenda, RE: Automobile Operating Expenses and Alterations to a Recreational Vehicle ("RV") This is in reply to your two email requests dated May 12 and May 31, 2005. ... Majerus, CA Senior Rulings Officer Income Tax Rulings Directorate Policy & Planning Branch Canada Revenue Agency (613) 832-3488 ...

26 August 2005 Internal T.I. 2005-0131171I7 F- Alinéa 18(1) e) de la LIR Unedited CRA Tags 18(1) e) Principales Questions: Peut-il y avoir obligation légale de payer lorsque l'obligation légale ou contractuelle n'identifie pas de tiers pour prendre paiement? ... Le 26 août 2005 Bureau des services fiscaux de Laval Administration centrale Michel Pelletier Jonathan Le Blanc Vérificateur de dossiers importants (613)957-2131 Section 441-0-0 2005-013117 XXXXXXXXXX Nous écrivons en réponse à votre note de service datée du 9 mai 2005 dans laquelle vous demandiez notre opinion sur une interprétation à donner à l'alinéa 18(1)e) de la Loi de l'impôt sur le revenu. ... Cette opinion est par ailleurs conforme à l'interprétation technique # 2004-008650117 traitant d'une matière semblable. ...

1 November 2005 External T.I. 2005-0121801E5- withholding of income tax on salary paid Unedited CRA Tags Reg. 102(1) Reg. 104(2) paragraph 153(1)(a) Principal Issues: Whether an employee who has a home in Canada but works for a U.S. employer and spends over 50% of his time working in the U.S. is subject to withholding of Canadian or U.S. income tax on his pay cheques? ... Reasons: Par. 153(1)(a), Reg. 102(1) and Reg. 104(2) require withholding of Canadian income tax by a resident and non-resident employer when the employee is a resident of Canada. 2005-012180 XXXXXXXXXX Catherine Bowen (613) 957-8284 November 1, 2005 Dear XXXXXXXXXX: Re: Withholding of income tax on salary paid to an employee This is in response to your letter dated February 21, 2005 wherein you requested our comments on whether an employee who has a home in Canada but works for a company in the United States of America (the "U.S. ... 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. ...

2005 Ruling 2004-0100611R3- Payment to Australia Unedited CRA Tags 212(1)(d) Principal Issues: Whether a payment for software to an Australian vendor is subject to withholding under Part XIII of the Income Tax Act. ... XXXXXXXXXX 2004-010061 XXXXXXXXXX, 2005 Dear XXXXXXXXXX: Re: Advance Income Tax Ruling XXXXXXXXXX ("NRco") This is in reply to your letter of XXXXXXXXXX, wherein you requested an advance income tax ruling on behalf of the above-referenced taxpayer, with respect to the sale of certain computer software called XXXXXXXXXX (the "Software"), to XXXXXXXXXX (the "Purchaser"). ... The unit price for 1-2 copies of the Software is $XXXXXXXXXX USD + $XXXXXXXXXX USD shipping. ...

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). ... Reasons: Wording of subparagraph 212(1)(d)(vi) and Articles VII and XII of the Canada-US Tax Convention; facts on hand. 2004-008663 XXXXXXXXXX Catherine Bowen (613) 957-8284 June 14, 2005 Dear XXXXXXXXXX: Re: Copyright Royalties under Subparagraph 212(1)(d)(vi) This is in response to your letter dated July 23, 2004, wherein you requested our comments on whether withholding taxes are applicable on royalties paid by a Canadian resident to residents of the United States under a licensing agreement. ...

2005 Ruling 2005-0146021R3- ATR-Deduct. of Shareholder/Manager Remuneration. ... XXXXXXXXXX 2005-014602 XXXXXXXXXX, 2005 Dear XXXXXXXXXX: Re: Advance Income Tax Ruling Request- XXXXXXXXXX This is in reply to your letter of XXXXXXXXXX, in which you requested an advance income tax ruling in respect of the above-noted company as it pertains to the deductibility of shareholder/manager remuneration. ... The shareholdings of Direct Shareholder D are as follows: Shareholders Common Shares % Indirect Shareholder A XXXXXX XXXXXXX Indirect Shareholder B XXXXXX XXXXXXX Indirect Shareholder C XXXXXX XXXXXXX Total XXXXXX XXXXXXX 13. ...

26 October 2005 External T.I. 2005-0152201E5- Positions in IT-114 Unedited CRA Tags 20(1)(f) Principal Issues: Whether positions in paragraphs 11 and 16 of cancelled IT-114 are still valid Position: General comments given Reasons: N/A XXXXXXXXXX 2005-015220 G. Moore October 26, 2005 Dear XXXXXXXXXX: Re: Interpretation Bulletin IT-114 This is in response to your recent enquiry about Interpretation Bulletin IT-114, Discounts, premiums and bonuses on debt obligations. ... In response to question # 20 at the 1994 Association de Planification fiscale et financière (APFF) Conference Round Table, CRA explained that: "Interpretation Bulletin IT-114, issued in 1973, was cancelled in full because it did not reflect significant changes to the Income Tax Act and was no longer a useful guide to the taxation of discounts, premiums and bonuses relating to a multiplicity of financial products that have changed considerably. ...

4 November 2005 External T.I. 2004-0104951E5- 104(4)(a.3)&104(5) pertains depreciable property Unedited CRA Tags 104(5) Principal Issues: Is there a deemed disposition on depreciable property used in a business carried on in Canada by a trust where the business has been transferred to a spousal trust in anticipation of the emigration of the settlor and his spouse? ... XXXXXXXXXX 2004-010495 Annemarie Humenuk Attention: XXXXXXXXXX November 4, 2005 Dear Sirs: Re: Deemed Disposition of Depreciable Property This is in reply to your letter of November 19, 2004, in which you ask for clarification of the application of subsection 104(5) to depreciable property used in a business carried on in Canada that has been transferred to a spousal trust under subsection 73(1) in anticipation of the transferor ceasing to be resident in Canada. ... Murphy Section Manager for Division Director International & Trusts Division Income Tax Rulings Directorate Policy and Planning Branch ...