Search - 2005年 抽纸品牌 质量排名

2005 Ruling 2005-0118591R3- RRSP Damages Unedited CRA Tags 146(5) 146(8) 204.2(1.2) 6 Principal Issues: Employee and her husband suffered investment losses in registered and non-registered accounts managed by employer, including a group retirement savings plan (GRSP) offered by the employer to its employees as a benefit of employment. ... XXXXXXXXXX 2005-011859 XXXXXXXXXX 2005 XXXXXXXXXX: Re: Advance Income Tax Ruling Request XXXXXXXXXX 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. ... " means XXXXXXXXXX. Facts 1. The Employee is a resident of the city of XXXXXXXXXX. ...

2005 Ruling 2005-0152491R3- windup of a mutual fund trust Unedited CRA Tags 132(6.2) 108(2)(a) Principal Issues: Will the suspension of the right to redeem units during the notice period required by the terms of the trust in order to vote on the termination of the trust cause the trust to lose its status as a unit trust within the meaning of 108(2)(a)? ... XXXXXXXXXX 2005-015249 Attention: XXXXXXXXXX XXXXXXXXXX, 2005 Dear XXXXXXXXXX: Re: XXXXXXXXXX Advance Income Tax Ruling This is in reply to your letter of XXXXXXXXXX in which you request an advance income tax ruling in respect of the above-noted taxpayer. ... XXXXXXXXXX Section Manager for Division Director International & Trusts Division Income Tax Rulings Directorate Policy and Planning Branch ...

2005 Ruling 2005-0148251R3- Disposition of Taxable Canadian Property Unedited CRA Tags 116(3) 116(5) Article 13 Canada-Finland Treaty Principal Issues: Will the taxpayer's disposition of taxable Canadian property be subject to Canadian income tax? ... XXXXXXXXXX 2005-014825 XXXXXXXXXX, 2005 Dear XXXXXXXXXX: Re: XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX Advance Income Tax Ruling This is in response to your XXXXXXXXXX request for an advance income tax ruling on behalf of the above taxpayers. ... Yours truly, XXXXXXXXXX for Director International & Trusts Division Income Tax Rulings Directorate Policy and Planning Branch ...

2005 Ruling 2004-0060241R3- XXXXXXXXXX Unedited CRA Tags 149(1)(c) 75(2) 104(6) 107(2) Principal Issues: 1. ... The First Nation will be the sole contributor of funds to the trust, and is the sole beneficiary (?) ... Canada asserted that the First Nations were "XXXXXXXXXX ", at the time of this surrender in XXXXXXXXXX. 8. ...

2005 Ruling 2005-0119091R3- Withholding tax; interest Unedited CRA Tags 212(1)(b)(vii) 245(2) Principal Issues: Whether GAAR applies. ... Partnership will assume the O & M Agreement such that the XXXXXXXXXX Assets will be operated in substantially the same manner a before their transfer to Partnership. 18. ... It is not anticipated that any prospective Debenture Holder will hold more than XXXXXXXXXX % of the units of Income Fund. ...

2005 Ruling 2005-0133281R3- License Amortization and Financing Fees Unedited CRA Tags 20(1)(E) CLASS 14 20(1)(A) 20(1)(C) Principal Issues: License Agreement for 30 years for completing project Position: Acceptable Reasons: Given before in 2004-0105611 XXXXXXXXXX 2005-013328 XXXXXXXXXX, 2005 Dear XXXXXXXXXX: Re: Advance Income Tax Ruling XXXXXXXXXX XXXXXXXXXX This is in response to your letter of XXXXXXXXXX and further to your revision of XXXXXXXXXX, wherein you requested an advance income tax ruling in respect of the above named taxpayers. ... The construction of the Facility is expected to last for a period of approximately XXXXXXXXXX years; (e) "Contract Period" is the period that includes the Construction Period and the Operating Period and is expected to last for a period of XXXXXXXXXX years; (f) "Contractor" means the joint venture between XXXXXXXXXX (a wholly-owned subsidiary of Z Co) and XXXXXXXXXX that will design and build the Project under an EPC Contract with the Partnership; (g) "CRA" means Canada Revenue Agency; (h) "Entity " is the XXXXXXXXXX; (i) "EPC Contract" means the engineering, procurement and construction contract between the Partnership and the Contractor; (j) "Facility" is the proposed XXXXXXXXXX; (k) "GP" is XXXXXXXXXX; (l) "Licence" is the non-exclusive licence that the Province will grant to the Partnership, pursuant to the Concession Agreement, to provide the Partnership with rights of use and access to the Site and the Facility, for the purposes of constructing the Facility and providing services during the Operating Period; (m) "Loan Agreement" is the agreement between XXXXXXXXXX and XXXXXXXXXX (collectively the "Lenders"), the Partnership, and GP pursuant to which the Lenders will make a loan to the Partnership; (n) "Operating Period" is the part of the Contract Period that begins immediately after the Construction Period and ends at the end of the Contract Period; (o) "Partnership" is a limited partnership formed under the laws of XXXXXXXXXX called the XXXXXXXXXX, with Z Co as the limited partner and XXXXXXXXXX as the general partner; (p) "Project" is the XXXXXXXXXX; (q) "Province" is the Province of XXXXXXXXXX; (r) "Site" is the land on which the Facility will be constructed; (s) "Substantial Completion" means the substantial completion of the construction of the Facility as outlined in the Concession Agreement; (t) "Taxable Canadian corporation" has the meaning assigned by subsection 89(1) of the Act; (u) "TSO" means Tax Services Office; and (v) "Z Co" is XXXXXXXXXX. ...

2005 Ruling 2005-0153941R3- Withholding Tax Rate Unedited CRA Tags 212(2) Article X, paragraph 2, Canada-US Treaty Article XXIX-A, paragraph 7 Canada-US Treaty Principal Issues: Whether the 5% reduced withholding rate, pursuant to paragraph 2 of Article X of the Canada-US Treaty, applies to the proposed dividend(s) from a Canadian corporation, through a partnership, to US partners that are issued more than 10% of the voting shares of the Canadian corporation that is paying the dividend. ... XXXXXXXXXX 2005-015394 XXXXXXXXXX, 2005 Dear XXXXXXXXXX: Re: XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX. ... Yours truly, XXXXXXXXXX for Director International & Trusts Division Income Tax Rulings Directorate Policy and Planning Branch ...

2005 Ruling 2004-0105821R3- Loss utilization Unedited CRA Tags 20(1)(c) 112(1) 246(1) 84(3) Principal Issues: Loss utilization within a corporate group Position: Acceptable Reasons: Meets the technical requirements of the provisions XXXXXXXXXX 2004-010582 XXXXXXXXXX, 2005 Dear XXXXXXXXXX: Re: Advance Income Tax Ruling XXXXXXXXXX XXXXXXXXXX This is in reply to your letter of XXXXXXXXXX requesting an advance income tax ruling on behalf of the above named corporations. ... As at its taxation year-end-XXXXXXXXXX- A Co had accumulated non-capital losses in the amount of $XXXXXXXXXX. $ XXXXXXXXXX of the accumulated non-capital losses was incurred in XXXXXXXXXX and the balance is a carry forward from XXXXXXXXXX. 4. ...

2005 Ruling 2005-0113301R3- Butterfly Unedited CRA Tags 55(3)(b) Principal Issues: Whether the proposed transactions meet the exemption under paragraph 55(3)(b)? ... XXXXXXXXXX 2005-011330 XXXXXXXXXX, 2005 Dear XXXXXXXXXX: Re: XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX This is in reply to your letter dated XXXXXXXXXX, wherein you requested an advance income tax ruling on behalf of the above-noted taxpayers. ... XXXXXXXXXX Class D preferred shares which are held by XXXXXXXXXX (the "Trust D"), with an aggregate PUC of $ XXXXXXXXXX and an aggregate ACB of $XXXXXXXXXX; b. ...

2005 Ruling 2005-0130541R3- Participating Interest Unedited CRA Tags 20(1)(c) Principal Issues: Can the Additional Interest paid or payable be deducted under paragraph 20(1)(c) provided it does not exceed a reasonable amount? ... XXXXXXXXXX 2005-013054 XXXXXXXXXX, 2005 Dear XXXXXXXXXX: Re: Advance Income Tax Ruling XXXXXXXXXX XXXXXXXXXX This is in reply to your letter of XXXXXXXXXX and further to our electronic messages of XXXXXXXXXX wherein you request an advance income tax ruling on behalf of the above named taxpayers. ... DEFINITIONS In this letter, the following terms are defined as follows: (a) "A Co" means XXXXXXXXXX; (b) "A Co Shareholder" means a beneficial owner of one or more A Co common shares but does not include a XXXXXXXXXX; (c) XXXXXXXXXX; (d) "ACB" means adjusted cost base and has the meaning assigned by section 54 of the Act; (e) "AcquisitionCo" means XXXXXXXXXX, a Taxable Canadian Corporation incorporated under the XXXXXXXXXX, all of the shares of which are held by LP; (f) "Additional Interest" will be payable annually by the Debtor and will be equal to the lesser of a specific percentage amount of the outstanding principal amount of the Debt, currently estimated to be XXXXXXXXXX% per annum (being an amount intended to increase the effective interest rate on the Debt to the prevailing market rate of interest for comparable debt), and an amount equal to the taxable income of the Debtor minus $XXXXXXXXXX calculated without regard to the Additional Interest component; (g) XXXXXXXXXX; (h) "Base Interest" means interest at a fixed rate, currently estimated to be XXXXXXXXXX% per annum, of the outstanding principal amount of the Debt that will be payable annually by the Debtor; (i) "Combination" means the proposed combination into one corporation, (XXXXXXXXXX) of all assets and liabilities of AcquisitionCo, A Co, the XXXXXXXXXX and the subsidiaries by way of the amalgamation of such corporations under subsection 87(1) of the Act; (j) "CombinationCo" means the corporation that will be created as a result of the amalgamation of AcquisitionCo, A Co, the XXXXXXXXXX and the subsidiaries; (k) "CRA" means the Canada Revenue Agency; (l) "Debt" means the debt to be issued by AcquisitionCo to LP as outlined in the Proposed Transactions, the terms and conditions of which will include interest at a maximum rate, currently estimated to be XXXXXXXXXX% per annum, payable annually and comprised of (i) Base Interest, and (ii) Additional Interest; with any Interest that has become payable but has not been paid within a specified period of time being added to the principal amount of the Debt then outstanding; (m) "Debtor" means the debtor under the Debt, which initially will be AcquisitionCo and as more fully outlined under the Proposed Transactions, will be CombinationCo when certain corporations are amalgamated with AcquisitionCo; (n) "FMV" means fair market value; (o) "GAAR" means the general anti-avoidance rule under section 245 of the Act; (p) "GPCo" means a Taxable Canadian Corporation incorporated under the XXXXXXXXXX to function as administrator of the MFT and the Trust, the general partner of LP, and whose share capital is wholly-owned by the MFT; (q) "XXXXXXXXXX" means a Taxable Canadian Corporation incorporated under the XXXXXXXXXX, all or substantially all of the assets of which will be common shares of XXXXXXXXXX; (r) "XXXXXXXXXX" means a person that beneficially owns one or more XXXXXXXXXX; (s) "XXXXXXXXXX" means shares in the capital of XXXXXXXXXX; (t) "Indenture" means the declaration of trust to be made by the trustee of the Trust to, among other things, hold in trust any and all property of the Trust and any income and gains therefrom for the benefit of the beneficiary of the Trust; (u) "Interest" means the interest payable in respect of the principal amount owing under the Debt from time to time, comprised of the Base Interest plus the Additional Interest; (v) "LP" means a limited partnership formed under the XXXXXXXXXX pursuant to the LP Agreement; (w) "LP Agreement" means the written partnership agreement entered into between GPCo, as general partner, and the Trust as limited partner of the LP; (x) "LP Unit" means an interest in the LP's capital issued pursuant to the terms of the LP Agreement; (y) "mutual fund trust" has the meaning assigned by subsection 132(6); (z) "MFT" means a mutual fund trust created and governed under the laws of the Province of XXXXXXXXXX and formed pursuant to the MFT Indenture; (aa) "MFT Indenture" means the declaration of trust made by the trustee of MFT to, among others, hold in trust any and all property of the MFT and any income and gains therefrom, for the benefit of the MFT Unitholders; (bb) "MFT Unitholder" means a holder of a MFT Unit; (cc) "MFT Unit" means a trust unit of MFT, each such unit representing an equal fractional undivided beneficial interest in any distributions from the MFT and in any net assets of the MFT in the event of termination of the MFT; (dd) "XXXXXXXXXX Partnership" means a partnership formed under the XXXXXXXXXX pursuant to a written partnership agreement having a PartnerCo and one or more subsidiaries as its only partners; (ee) "Option" means an option to acquire an A Co common share pursuant to an agreement as contemplated under subsection 7(1) of the Act; (ff) "PartnerCos" means those Taxable Canadian Corporations, each of which is wholly-owned indirectly by MFT, that hold an interest in one or more of the XXXXXXXXXX Partnerships and that will remain as separate corporations holding such direct interest in one or more of the XXXXXXXXXX Partnerships after the Combination; (gg) "Proposed Transactions" means those transactions and events described in paragraphs 13 to 17; (hh) "Public Corporation" has the meaning assigned by subsection 89(1) of the Act; (ii) "XXXXXXXXXX " means those Taxable Canadian Corporations formed under the XXXXXXXXXX that are either wholly-owned by A Co or another subsidiary; (jj) "Taxable Canadian Corporation" has the meaning assigned by subsection 89(1) of the Act; (kk) "Trust" means an inter vivos trust for purposes of the Act, to be created and governed under the laws of the Province of XXXXXXXXXX, the sole beneficiary of which will be the MFT; (ll) "Trust Note" means a promissory note evidencing a debt obligation issued by the trustee of Trust in accordance with the Trust Indenture; and (mm) XXXXXXXXXX. ...