Search - 2005年 抽纸品牌 质量排名

2005 Ruling 2005-0155371R3- Alter Ego Trust Planning Unedited CRA Tags 88(1)(d) 118.1 40(3.6) 88(1)(c.2)(ii) Principal Issues: 1. ... The officers of SOCIETY are as follows: Officer Title XXXXXXXXXX President XXXXXXXXXX Secretary & Treasurer 8. ... Its officers are as follows: Officer Title XXXXXXXXXX President XXXXXXXXXX Secretary & Treasurer 16. ...

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. ...

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. ...

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. ...

2005 Ruling 2005-0123631R3- Thin Capitalization Rules Unedited CRA Tags 18(4) 18(6) 245(2) Principal Issues: Whether subsection 18(6) of the Act will apply to the debts acquired by the partnership? ... CanCo owns approximately XXXXXXXXXX % of the common shares of ForeignCo, a corporation incorporated under the laws of XXXXXXXXXX and resident in that country for purposes of the Act. ... Yours truly, XXXXXXXXXX for Director International & Trusts Division Income Tax Rulings Directorate Policy and Planning Branch ...

Reasons: Previous rulings XXXXXXXXXX 2005-012415 XXXXXXXXXX, 2005 Dear XXXXXXXXXX: Re: XXXXXXXXXX Advance Income Tax Ruling Request This is in reply to your letter of XXXXXXXXXX, in which you request an Advance Income Tax Ruling on behalf of the above named taxpayer. ... XXXXXXXXXX GP owns a XXXXXXXXXX % general partnership interest and XXXXXXXXXX LP Inc. owns a XXXXXXXXXX% limited partnership interest. ... Yours truly, XXXXXXXXXX Section Manager For Division Director International & Trusts Division Income Tax Rulings Directorate Policy and Planning Branch ...

(Opco & Holdco amalgamate to form Amalco I. A subsidiary corporation (GPco) 100% owned by Fund will be created. GPco & Amalco I will form a Partnership with Amalco I transferring all former operating assets on a rollover basis. ... Newco & Amalco I will amalgamate to form Amalco II. Fund will use 132.2 to acquire all the assets of Amalco II and become the limited partner of the Partnership. ...

2005 Ruling 2004-0108281R3- Inducement payment and ACB of shares Unedited CRA Tags 12(1)(x) Principal Issues: (a) whether an amount is included in computing income under paragraph 12(1)(x) of the Act. ... XXXXXXXXXX 2004-010828 XXXXXXXXXX, 2005 Dear XXXXXXXXXX: Re: Advance Income Tax Ruling XXXXXXXXXX XXXXXXXXXX This is in response to your letter dated XXXXXXXXXX, wherein you requested advance income tax rulings on behalf of the above-noted taxpayers. ... Additionally, B Co owns XXXXXXXXXX shares of A Co representing XXXXXXXXXX % of the issued and outstanding shares of A Co which it acquired during the period commencing in XXXXXXXXXX and ending in XXXXXXXXXX. ...

2005 Ruling 2004-0108821R3- MIC as a limited partner Unedited CRA Tags 253.1 130.1(6)(b) Principal Issues: Whether a corporation's status as a MIC would be jeopardized if it acquires a XXXXXXXXXX % limited partnership interest. ... XXXXXXXXXX 2004-010882 XXXXXXXXXX, 2005 Dear XXXXXXXXXX: Re: Advance Income Tax Ruling Request XXXXXXXXXX This is in reply to your letter dated XXXXXXXXXX in which you requested an advance income tax ruling on behalf of the above-noted taxpayer. ...

2005 Ruling 2005-0120761R3- Withholding Tax exemption Unedited CRA Tags 212(1)(b)(vii) 212(13.2) Principal Issues: Where a corporation is deemed to be a resident of Canada pursuant to subsection 212(13.2), can it avail itself of the 212(1)(b)(vii) exemption if it qualifies? Position: YES Reasons: reading of 212(13.2) with 212(1)(b)(vii) XXXXXXXXXX 2005-012076 XXXXXXXXXX, 2005 Dear XXXXXXXXXX: Re: Advance Income Tax Ruling XXXXXXXXXX ("A Co") This is in reply to your letter of XXXXXXXXXX, wherein you request an advance income tax ruling on behalf of the above named corporation. ... $XXXXXXXXXX in additional equity (the " Equity Issue"), before expenses. 5. ...