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Technical Interpretation - External summary

28 August 2009 External T.I. 2009-0325881E5 F - Application of Subsection 89(8) -- summary under Subsection 89(8)

The correspondent stated that “no amount could be determined for Target in respect of element I in the formula provided for in element H of subsection 89(8) since the definition of general rate income pool ("GRIP") is not applicable for the 2005 taxation year” suggested that there appeared to be an overstatement (from a policy perspective) of Target's LRIP “resulting from its inability to benefit from the GRIP balance that it would have otherwise enjoyed had its change in status occurred after January 1, 2006.” CRA responded: [S]ubsection 89(8) is technically applicable …. [R]esponsibility for tax policy rests with the Department of Finance ….” ...

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