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Administrative Letter
28 June 1989 Administrative Letter 58256 F - Transfer Provisions of Funds Between RRPs and RRSPs
28 June 1989 Administrative Letter 58256 F- Transfer Provisions of Funds Between RRPs and RRSPs Unedited CRA Tags n/a 19(1) File No. 5-8256 F. Francis (613) 957-3496 June 28, 1989 Dear Sirs: This is in reply to your letter of June 14, 1989, wherein you requested our comments in respect of the draft legislation on the transfer provisions of funds between registered pension plans ("RPP") and registered retirement savings plans ("RRSP"). ...
Administrative Letter
11 December 1990 Administrative Letter 902766 F - Eligibility of Cost of Renting Cinitron Bed as Medical Expense
11 December 1990 Administrative Letter 902766 F- Eligibility of Cost of Renting Cinitron Bed as Medical Expense Unedited CRA Tags n/a 24(1) 902766 M. Eisner (613) 957-2138 19(1) December 11, 1990 Dear Sirs: This is in reply to your letter of September 25, 1990 concerning whether the cost of renting a Clinitron bed can be treated as a medical expense for income tax purposes. ...
Administrative Letter
2 April 1990 Administrative Letter 59686 F - Impact of 1990 Budget on Withdrawals from RESP Acquired Prior to Budget Date
2 April 1990 Administrative Letter 59686 F- Impact of 1990 Budget on Withdrawals from RESP Acquired Prior to Budget Date Unedited CRA Tags 146.1, 56(1)(q) 19(1) File No. 5-9686 A.B. Adler (613) 957-8962 April 2, 1990 19(1) This is in reply to your letter dated February 28, 1990 in which you requested our views concerning the impact of certain budget proposals of February 20, 1990 upon the income tax treatment of withdrawals of income from a registered education savings plan ("RESP") that was acquired prior to that date. ...
Administrative Letter
18 October 1990 Administrative Letter 901436 F - Subsidiary's Expenditure Year where Transfer of Accounts to Parent on Winding-up
18 October 1990 Administrative Letter 901436 F- Subsidiary's Expenditure Year where Transfer of Accounts to Parent on Winding-up Unedited CRA Tags 88(1.3), 88(1)(e.3) 24(1) 901436 L.A. McCarron-McGuire (613) 957-2092 19(1) October 18, 1990 Dear Sirs: Re: Technical Interpretation Subsection 88(1.3) of the Income Tax Act (the "Act") We are writing in response to your letter dated July 10, 1990 regarding the omission in paragraph 88(1.3)(a) of the Act of any reference to the subsidiary's "expenditure year". ...
Administrative Letter
27 February 1990 Administrative Letter 59516 F - Shareholder Debt Benefit
27 February 1990 Administrative Letter 59516 F- Shareholder Debt Benefit Unedited CRA Tags 15(2) 19(1) File No. 5-9516 C. Robb (613) 957-2744 February 27, 1990 Dear Sirs: Re: Subsection 15(2) of the Income Tax Act (the "Act") We are writing in response to your letter of January 29, 1990 in which you requested our views concerning subsection 15(2) of the Act and its application where a non-resident corporation connected with a shareholder of a Canadian company ("Canco") collects the accounts receivable of Canco and pays interest to Canco at a prescribed rate on the average monthly balance outstanding. ...
Administrative Letter
14 February 1990 Administrative Letter 32840 F - Request for Advance Income Tax Ruling
14 February 1990 Administrative Letter 32840 F- Request for Advance Income Tax Ruling Unedited CRA Tags n/a 19(1) 3-2840 J.D. Brooks (613) 957-2097 Dear Sirs: Re: 24(1) Request for Advance Income Tax Ruling We are writing in response to your letter of November 20, 1989 in which you requested an advance income tax ruling for 24(1) and further to our recent telephone conversations (Brooks) We have completed our initial review of your request and have a number of questions. ...
Administrative Letter
14 August 1990 Administrative Letter 900926 F - Payment to Former Independent Contractor
14 August 1990 Administrative Letter 900926 F- Payment to Former Independent Contractor Unedited CRA Tags 9 24(1) 900926 J.D. Jones (613) 957-2104 Attention: 19(1) EACC9315 August 14, 1990 Dear Sirs: Re: Payment to Former Independent Contractor This is in reply to your letter of May 18, 1990 wherein you requested our opinion on the tax consequences in the following circumstances. 24(1) It is your view that 24(1) Our Comments As discussed with you by telephone, we are unable to provide you with a definitive reply since your question depends primarily on a determination of what the relationship between the tax exempt entity and the individual is in fact. ...
Administrative Letter
20 November 1989 Administrative Letter 58666 F - Canada-U.S. Income Tax Convention on Capital Gains
Income Tax Convention on Capital Gains Unedited CRA Tags n/a 19(1) File No. 5-8666 O. Laurikainen (613) 957-2125 November 20, 1989 Dear Sirs: Re: Article XIII of the Canada-U.S. ...
Administrative Letter
27 November 1989 Administrative Letter 58896 F - Deferred Salary Leave Plan - Calculation of CPP and UI Premiums
27 November 1989 Administrative Letter 58896 F- Deferred Salary Leave Plan- Calculation of CPP and UI Premiums Unedited CRA Tags n/a 19(1) File No. 5-8896 W.C. Harding (613) 957-3499 November 27, 1989 Dear Sirs: This is in reply to your letter of September 13, 1989 addressed to our Source Deductions Division and referred to us for reply. ... The Department, in consultation with the Justice Department and the Departments of Finance, Employment and Immigration, and Health and Welfare, has determined that: a) U.I. premiums are to be based on the employee's gross salary before deferrals during the period of deferral and no premiums are to be withheld from the deferred amounts when paid to the employee during the leave period. b) C.P.P. premiums are to be based on the salary the employee actually receives during both the deferral period and the leave period. ...
Administrative Letter
11 July 1989 Administrative Letter 57856 F - Transferability of Annuity Payments to RRSP
11 July 1989 Administrative Letter 57856 F- Transferability of Annuity Payments to RRSP Unedited CRA Tags 17(8), 60(j) 19(1) File No. 5-7856 W.C. Harding (613) 957-3499 July 11, 1989 19(1) This is in reply to your letter of April 4, 1989 and in confirmation of our telephone conversation of June 22, 1989 19(1) Harding) concerning the transferability of your 24(1). ... In particular it is proposed that: a. lump sum transfers, such as upon commutation of a pension annuity, may only be transferred on a direct plan basis after January 1, 1989 and b. ...