Search - 德国民法典第1993条

1993 External T.I. 9335545 F- Sub — 256(2) and T2144 Unedited CRA Tags 256(2) 5-933554 XXXXXXXXXX Attention:  XXXXXXXXXX December 10, 1993 Dear Sir: RE:  Subsection 256(2) and Form T2144 We are writing in response to your letter of November 29, 1993 in which you have requested clarification of the Department's position concerning the election (Form T2144) available under subsection 256(2) of the Income Tax Act. ... Comments A directive signed by the Director of Audit Programs Division (Jean- Pierre Lavigne) was sent to all District Offices on October 21, 1993 advising that late-filed elections under subsection 256(2) on prescribed Form T2144 can now be accepted under certain conditions. ... Tim Bryant December 10, 1993 ...

1993 Internal T.I. 9332137 F- Farm Support Payments Unedited CRA Tags 12(1)(x) December 17, 1993 Client Assistance Directorate Head Office G. Levesque, Chief Rulings DirectorateOther Returns & Guides Division 957-8953 933213 Treatment of Permanent Cover Program This is in reply to your memorandum of November 4, 1993, referring to a memorandum dated August 13, 1993 dealing with a referral from the Winnipeg D.O. relating to the inclusion in income of payments received by farmers from Agriculture Canada- Prairie Farm Rehabilitation Administration ("PFRA") under the above-noted program. ... You expressed concern that the position set out in our August 13, 1993 memorandum was a change from that taken earlier in the document "TAX STATUS OF FARM SUPPORT PAYMENTS" which you state, "was straight forward with income being taxable under section 12(1)(x) or 80(1)". ...

AUTHOR SUBJECT OF CORPORATE CASE FILE April 29, 1993 XXXXXXXXXX Dear XXXXXXXXXX I am replying to your letter of March 15, 1993, to which you attached a letter received from some of your constituents, who are members of the staff of XXXXXXXXXX concerning the taxation of interest received on funds held in trust to provide funeral services. ... In subsequent meetings with representatives of The Funeral Service Association of Canada, the Department agreed to delay until 1993 the implementation of the changes set out in our letter of May 1, 1992. ... Minister of Finance Cal Brown 957-2131 930866 April 19, 1993 ...

23 June 1993 Income Tax Severed Letter 9308887 F- Revenu gagné hors réserve Unedited CRA Tags 81(1)a) 5(1) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... Le 23 juin 1993 Bureau de district d'Ottawa BUREAU PRINCIPAL Division validation et recouvrements Division des particuliers A l'attention de Mme Marie Levasseur et des entreprises de services (613) 957-8953 C. ... En assumant que XXXXXXXXXX réside dans une réserve et que XXXXXXXXXX soit un indien inscrit, celui-ci serait exempté d'impôt à l'égard de ce revenu d'emploi gagné en 1992 et 1993. ...

18 August 1993 Ruling 9321803 F- Capital Gains- Non-resident Entering Canada Unedited CRA Tags 110.6(5), 110.6(13), 110.6(3)   XXXXXXXXXX Dear XXXXXXXXXX RE:  XXXXXXXXXX XXXXXXXXXX Advance Income Tax Ruling This is in reply to your letter of July 12, 1993 requesting an advance income tax ruling on behalf of the above two named individuals with respect to the disposition of their rental property at XXXXXXXXXX As discussed with you over the telephone on August 6, 1993 we are unable to provide the ruling requested as it contains tax-related calculations and the transaction, though contemplated, is indefinite. ... In the case of individuals becoming resident in Canada part-way through 1992, they would not be deemed to be resident in Canada throughout 1992 for purposes of claiming the capital gains deduction in that year until they in fact had been resident for the full 1993 taxation year. This will require filing amended 1992 tax returns following December 31, 1993 as they could not initially claim the capital gain deduction when filing the original 1992 tax returns. ...

1993 External T.I. 9325585 F- Automobile Expense Benefit Unedited CRA Tags 6(1)(k) XXXXXXXXXX 932558 Attention:  XXXXXXXXXX January 7, 1994 Dear Sirs: RE:  Subsection 6(1)(k)-Automobile Expense Benefit We are writing in response to your letter of September 3, 1993, wherein you requested our views regarding the application of section 6(1)(k) of the Draft Legislation issued by the Department of Finance in August, 1993 dealing with proposed amendments to the Income Tax Act (the "Act") and relating to the above subject matter. We also refer to our telephone conversation of December 8, 1993 (Charest/Larochelle). ... For 1993 and subsequent taxation years, the automobile operating expense benefit of such an employee shall be determined as the prescribed amount (presently proposed at 12 cents) for every such kilometre driven, less any reimbursements to the payor in respect of operating expenses. ...

28 January 1993 Income Tax Severed Letter 9237595- Home Buyers Plan Unedited CRA Tags 146.01 5-923759 XXXXXXXXXX Robert Gagnon (613) 957-8953 January 28, 1993 Dear Sir: Re: Home Buyers' Plan This is in reply to your letter of December 2, 1992 wherein you requested an advance ruling concerning the Home Buyers' Plan ("HBP"). ... Where you acquire the qualifying home before you make any withdrawals, you must be resident of Canada at the time funds are withdrawn; 4. you entered into an agreement in writing for the acquisition of a qualifying home or with respect to its construction, before the time funds are withdrawn; 5. if funds are withdrawn before March 2, 1993, you generally must (an exception apply in certain circumstances) acquire the qualifying home (or a replacement property) after February 25, 1992 and before October 1, 1993. ... For instance, if you are entitled to take possession of your condominium unit on July 1, 1993, you are deemed to have acquired the unit at that date. ...

2 December 1993 Income Tax Severed Letter 933330A F- Non-Resident Exercises Stock Option (4093-U5-100-15) Unedited CRA Tags 7(1), 7(4), 115(1)(a)(i), 7(3)(b), Art 15 EXAMPLE Facts Mr. ... X exercised his option in 1993 and the benefit under section 7(1) was $45,000 (Canadian). ... X would be required to include in income the total benefit of $45,000 (Canadian) in income in 1993 in accordance with subsections 7(1), 7(4), 2(3) and 115(1) of the Income Tax Act (the "Act"). ...

23 December 1993 Income Tax Severed Letter 9307687- Exempt Income—Federal Abatement—SBD Unedited CRA Tags 149(1)(t) 124(1) 125(1) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... December 23, 1993 London District Office Head Office Business Enquiries Rulings Directorate (613) 957-8953 Attention: Morris Zambon / Katherine Kiar 930768 Paragraph 149(1)(t) and Subsections 124(1) and 125(1) This is in reply to your memorandum of March 17, 1993, concerning the anomaly resulting when a taxpayer entitled to tax exemption under paragraph 149(1)(t) claims the 10% tax abatement under subsection 124(1). ... We enclose for your files a copy of the letter, dated December 2, 1993, from Appeals to T2 Assessing advising them of their recommendation. ...

9 March 1993 Income Tax Severed Letter 9305485- Specified Leasing Property Unedited CRA Tags 16.1 REG 1100(1.11) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... Cooke (613) 957-8972 Attention: XXXXXXXXXX March 9, 1993 Dear Sirs: Re: "Exempt Property" of the "Specified Leasing Property Rules" This is in reply to your letter of February 17, 1993, in which you request that we reconsider our position, as stated in our letter of January 8, 1993, regarding the above noted subject. ...