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Ruling

2005 Ruling 2005-0111421R3 - Sequential Spin-off Butterfly Reorganization

2005 Ruling 2005-0111421R3- Sequential Spin-off Butterfly Reorganization Unedited CRA Tags 55(3)(b) Principal Issues: Sequential Spin-off Butterfly Reorganization- Several Issues. ... XXXXXXXXXX 2005-011142 XXXXXXXXXX, 2005 Dear XXXXXXXXXX: RE: XXXXXXXXXX ("DC") XXXXXXXXXX ("DC Sub") Advance Income Tax Ruling Request This is in reply to your letter of XXXXXXXXXX, and your subsequent correspondence wherein you requested an advance income tax ruling on behalf of the above-noted taxpayers. ... The TC Special Shares will have the following terms and conditions: (a) each TC Special Share will be redeemable, subject to applicable law, at any time at the option of TC at a redemption amount equal to the aggregate FMV of the consideration for which such share was issued divided by the total number of issued TC Special Shares (plus any declared but unpaid dividends); (b) each TC Special Share will be retractable, subject to applicable law, at any time at the option of the holder at a retraction amount equal to the redemption amount described above; (c) the holder of each TC Special Share will be entitled to a non-cumulative XXXXXXXXXX % cash dividend as and when declared by the board of directors from time to time, which dividend need not also be declared on any other class of shares of TC; (d) there will be a provision restricting the payment of dividends on other classes of shares so that no such dividends may be paid on any other class of shares of TC if the resulting realizable value of the net assets of TC after payment of the dividends would be less than the aggregate of the redemption amounts of all of the TC Special Shares then outstanding; (e) the holder of each TC Special Share will be entitled, upon the liquidation, dissolution or winding-up of TC, to a payment in priority to all other classes of shares of TC ranking junior to the TC Special Shares of an amount equal to the redemption amount thereof to the extent of the amount or value of property available under applicable law for payment to shareholders upon dissolution, but will be entitled to no more than the amount of that payment; and (f) the holder of each TC Special Share will not be entitled to vote at meetings of shareholders of TC. 36. ...
GST/HST Ruling

10 January 2005 GST/HST Ruling 49116 - Importation of the XXXXX

The policy lists certain factors that might be considered in making this determination, including: •   the type of home or trailer in question; •   the use of the home and the applicable land; •   the actual degree of permanency with the land; •   applicable provisions of any agreements relating to the permanency and means of affixation of the home or trailer to the land; and •   the removal or ownership of the home or trailer at the end of the lease. ... In addition to the indicators of permanence listed in P-104, the following may be considered when determining whether a "residential unit" is affixed to its site: •   the unit is connected to utilities; •   the unit is placed on concrete pads and skirted; •   the unit is left in place for an indefinite period of time; •   the unit is available for use on a year round basis; and •   the unit is used often enough to constitute a place of residence. ... Yours Truly, Paul Hawtin Rulings Officer Financial Institutions and Real Property Division Excise and GST/HST Rulings Directorate 2005/01/19 RITS 50163 The Transfer of Units in Gross Royalty Trusts ...
GST/HST Ruling

24 October 2005 GST/HST Ruling 58545 - Sale of Vacant Land

24 October 2005 GST/HST Ruling 58545- Sale of Vacant Land Unedited CRA Tags ETA 123(1) residential complex; ETA 123(1) residential unit; ETA 136(2); ETA Sch V, Part I, 5 Please note that the following document, although correct at the time of issue, may not represent the current position of the Agency. / Veuillez prendre note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'Agence. ... Section 5 of Part I of Schedule V generally provides that the subsequent sale of the multiple unit residential complex is an exempt supply provided that: •   ITCs were not claimed with respect to the last acquisition of or improvements made to the complex after the complex was last acquired by the builder; and •   after the complex was last received by the builder, there was not a substantial renovation of the complex. ... Antonelli Real Property Unit Financial Institutions and Real Property Division Excise and GST/HST Rulings Directorate 2005/10/06 RITS 60011 Application of GST/HST to [Fortifying Fruit Beverages] ...
Archived CRA website

ARCHIVED - 5013-G - General Income Tax and Benefit Guide for Non-Residents and Deemed Residents of Canada - 2005 - Getting started

For more information, see " What do you include with your return and what records do you keep? ... If you have to file a return for 2005, make sure you file it on time even if some slips or receipts are missing. ... Previous page | Table of contents | Next page Date modified: 2006-03-03 ...
GST/HST Interpretation

19 December 2005 GST/HST Interpretation 63297 - Application of the Goods and Services Tax (GST)/Harmonized Sales Tax (HST) to a Certain Management and Operating Lease Agreement

19 December 2005 GST/HST Interpretation 63297- Application of the Goods and Services Tax (GST)/Harmonized Sales Tax (HST) to a Certain Management and Operating Lease Agreement Unedited CRA Tags ETA 171(3); ETA 173(4); ETA 200(2); ETA 209(1); ETA Sch V, Part V.1, 1; ETA Sch V, Part VI, 1; ETA Sch V, Part VI, 25 Please note that the following document, although correct at the time of issue, may not represent the current position of the Agency. / Veuillez prendre note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'Agence. ... However, there are some indications that the Agreement is best characterized as a supply of the Property by way of lease from the Centre to the Auxiliary. •   There is a demise of property. ... If you require clarification with respect to the issues discussed in this letter, please call me at 613-954-4393. 2005/12/08 RITS 63606 Used Movie Video/DVD Exchanged for Credits ...
GST/HST Interpretation

27 January 2005 GST/HST Interpretation 53352 - Sections 7, 9 and 13 of Part II of Schedule V to the Excise Tax Act

27 January 2005 GST/HST Interpretation 53352- Sections 7, 9 and 13 of Part II of Schedule V to the Excise Tax Act Unedited CRA Tags ETA Sch VI, Part II, 5 Please note that the following document, although correct at the time of issue, may not represent the current position of the Agency. / Veuillez prendre note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'Agence. ... This positive pressure supports and holds the upper airway open to maintain uninterrupted breathing so that the respiratory process is not interrupted during sleep. •   An individual with a blocked or collapsed airway is considered to have a respiratory disorder because this condition prevents sufficient air from reaching the lungs to fully inflate them and interrupts the breathing process. •   The XXXXX machine is small and lightweight and was developed for home use. ... Yours truly, Susan Eastman Municipalities and Health Care Services Unit Public Service Bodies and Governments Division 2005/01/21 RITS 53556 Clarification of Band-Empowered Entities (BEEs): The Status of XXXXX ...
Archived CRA website

ARCHIVED - 5013-G - General Income Tax and Benefit Guide for Non-Residents and Deemed Residents of Canada - 2005 - Elections Canada

To remove your information from the Register, see " Confidentiality ", below. ... Contacting Elections Canada Telephone: (613) 993-2975 or 1-800-463-6868 toll free in Canada and the United States. (613) 993-2975 from outside Canada and the United States Teletypewriter: 1-800-361-8935 (for individuals with a hearing or speech impairment) toll free in Canada and the United States Internet: www.elections.ca Previous page | Table of contents | Next page Date modified: 2006-03-03 ...
Archived CRA website

ARCHIVED - General Income Tax and Benefit Guide - 2005 : At your service

For more information, refer to Personal Information Bank Number CRA/P-PU-005 at http://infosource.gc.ca or in the Infosource book, or call us at one of the telephone numbers listed under " Contacting us ". ... A representative who calls after April 30 should use your return for 2005. ... Previous page | Table of contents | Next page Date modified: 2006-01-04 ...
Ruling

2005 Ruling 2005-0126111R3 - Spin-off butterfly

2005 Ruling 2005-0126111R3- Spin-off butterfly Unedited CRA Tags 55(3)(b) Principal Issues: Spin-off butterfly involving a public company- no types of property basis. ... XXXXXXXXXX 2005-012611 XXXXXXXXXX, 2005 Dear XXXXXXXXXX: RE: XXXXXXXXXX- Advance Income Tax Ruling Request This is in reply to your letter of XXXXXXXXXX, as modified by your subsequent correspondence, wherein you requested an advance income tax ruling on behalf of the above-noted taxpayer. ... Immediately after this share exchange, the FMV of each Participant's share of the capital stock of Spinco will approximate the amount determined by the formula (A x B/C) + D as set out in subparagraph (b)(iii) of the definition "permitted exchange" in subsection 55(1). ...
Ruling

2005 Ruling 2005-0151921R3 - Butterfly Distribution

2005 Ruling 2005-0151921R3- Butterfly Distribution Unedited CRA Tags 55(3)(b) 40(3.4) Principal Issues: Butterfly distribution- two distributing corporations owned equally by the same shareholders. ... XXXXXXXXXX 2005-015192 XXXXXXXXXX, 2005 Dear XXXXXXXXXX: Re: XXXXXXXXXX Advance Income Tax Ruling Request This is in reply to your letter of XXXXXXXXXX, as modified by your other correspondence, wherein you requested an advance income tax ruling on behalf of the above-noted taxpayers. ... The authorized share capital of each of the Sibling Holdcos will include a class of voting common shares (collectively referred to as "Sibling Holdco Common Shares") and four classes of non-voting, non-participating preferred shares share (each class of shares collectively referred to as "Sibling Holdco Class A Shares", "Sibling Holdco Class B Shares", "Sibling Holdco Class C Shares " and "Sibling Holdco Class D Shares", respectively), bearing a discretionary non-cumulative dividend of up to XXXXXXXXXX% per month and redeemable at the option of the corporation or shareholder for an amount equal to the fair market value of the amount received by the corporation as consideration for the issuance of such particular shares. 8. ...

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