Search - 德国民法典第1993条

25 February 1993 Income Tax Severed Letter 9302245- Non-capital Loss Carryback Unedited CRA Tags 87(2.11) 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. 930224 XXXXXXXXXX A. Seidel (613) 957-2120 Attention: XXXXXXXXXX February 25, 1993 Dear Sirs: This is in reply to your letter dated January 27, 1993 with respect to the deductibility of non-capital losses subsequent to an amalgamation of a parent ("Parentco") and its wholly-owned subsidiaries ("Subco"). ... However, we can advise you that Bill C-92 received second reading in the House of Commons on February 25, 1993 and has now been referred to Committee. ...

28 September 1993 Income Tax Severed Letter 931361- Partnership—Canada-Egypt Tax Treaty 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. ... Harding (613) 957-2111 September 28, 1993 Dear Madam: Re: Canada-Egypt Income Tax Convention (the "Convention") This is in response to your fax (the "Fax") dated September 22, 1993 concerning the treatment of the income of Canadian partners who are members of an Egyptian partnership which carries on business in Egypt and not in Canada. ... As indicated in our letter of September 14, 1993 the Income Tax Conventions Interpretation Act ("ITCIA"), which was passed in Parliament and received Royal Assent, was enacted to ensure that the interpretation of any of Canada's tax treaties would not prevent Canada from taxing its residents on their world income. ...

25 August 1993 Income Tax Severed Letter 9319375 F- Deductibility of Life Insurance Premiums Unedited CRA Tags 20(1)e.2) 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. ... Shea-DesRosiers (613) 957-8953 A l'attention de XXXXXXXXXX Le 25 août 1993 Mesdames, Messieurs, Objet: Bulletin d'interprétation IT-309 La présente fait suite à votre lettre du 17 juin 1993. ...

22 September 1993 Administrative Letter 9322776 F- RRSP Advantage- Chance to Win a Prize Unedited CRA Tags 146(2)(c.4), 146(13.1) Registered Plans Division Financial Industries S.M. Kotlar, Division Director Attention:  Jeannine Lauzière XXXXXXXXXX This is in reply to your memorandum of June 18, 1993, which was received in this office on August 12, 1993, concerning the RRSP XXXXXXXXXX We have reviewed the material submitted with your memorandum and agree that the opportunity to win a prize by participating in the XXXXXXXXXX is not conditional in any way on the existence of a participant's RRSP. ...

1 November 1993 Ministerial Letter 9328758 F- Non-Resident Withholding Unedited CRA Tags 212(1)(b)(vii) MINISTER'S/DM'S OFFICE YS # 93-6065 ADM'S OFFICE RETURN TO RULINGS, ROOM 303, MET. BLDG XXXXXXXXXX Dear XXXXXXXXXX The Honourable Garth Turner, Minister of National Revenue, has asked me to reply to your letter of September 17, 1993, concerning a proposed exemption from non-resident withholding tax for payments under certain lease arrangements proposed or undertaken by XXXXXXXXXX Due to the confidentiality provisions of the Income Tax Act, I am unable to discuss the tax affairs of specific taxpayers with you without proper authorization. ... October 28, 1993 ...

6 December 1993 External T.I. 9326025 F- Shareholder Loans Unedited CRA Tags 15(2) XXXXXXXXXX  Attention:  XXXXXXXXXX Dear Sirs: RE:  Subsection 15(2) of the Income Tax Act (the Act) We are writing in response to your September 14, 1993 facsimile transmission regarding shareholder loans and public corporations (subsection 15(2) of the Act). ... Silden (1993) E.T.C. 2067 (FCA). In light of the Silden decision, the Department's position is currently under review and, accordingly, we are not able to provide you with a substantive reply at this time. ...

24 November 1993 Ministerial Letter 9333008 F- Williams Case Guidelines Unedited CRA Tags 80(1)(a) ADM'S OFFICE (3) ADM 931392 RETURN TO RULINGS, ROOM 303, MET. ... December 6, 1993 XXXXXXXXXX Dear XXXXXXXXXX Thank you for your submission of October 22, 1993, with respect to status Indian employees of XXXXXXXXXX XXXXXXXXXX We are presently consulting with interested parties to obtain assistance in the establishment of general guidelines using the principle of connecting factors as set out by the Supreme Court of Canada in the Glenn Williams case. ...

1993 External T.I. 9329315 F- Meaning of Grandchild Unedited CRA Tags 108(1) preferred beneficiary   XXXXXXXXXX 932931 Attention:  XXXXXXXXXX December 13, 1993 Dear Sirs: RE:  Subparagraph 108(1)(g)(iii) of the Income Tax Act (the "Act") This is in reply to your letter of October 4, 1993 concerning whether a step-child of a natural child of a settlor would qualify as a grandchild for purposes of subparagraph 108(1)(g)(iii) of the Act. ...

3 November 1993 External T.I. 9331330- Partie I.3 et avances Unedited CRA Tags 181.2(3)(c) DIRECTION DES DÉCISIONS    SOMMAIRE DE LA CORRESPONDANCE TYPE DE DOCUMENT: Réponse de table ronde PRINCIPALES QUESTIONS: Avances sur contrats visées à 181.2(3) POSITION ADOPTÉE: Incluses selon 181.2(3)c) RAISONS POUR POSITION ADOPTÉE: Avance comprend un montant reçu pour des services  à rendre ou des biens à fournir JURIDIQUE: Opinion 7181.2-2(1) du 26 octobre 1992 OPINION DE FINANCE: XXXXXXXXXX JURISPRUDENCE: s/o PUBLICATIONS DE REVENU CANADA IMPÔT: 1992 CPTS Roundtable Q.9 DOSSIER SUJET: HAA 1250-4 HAA 5638-3 Table ronde de l'APFF-Colloque "la taxe sur le capital" le 16 novembre 1993 Question 29. ... Ghislain Martineau 5-933133 3 novembre 1993 ...

22 February 1993 Income Tax Severed Letter 9303775- RRSP Investments — Promisory Notes 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.XXXXXXXXXX 5-930377 W.C. Harding (613) 957-8953 Attention: XXXXXXXXXX February 22, 1993 Dear Madam: Re: Promissory notes as RRSP Investments This is in reply to your letter of February 9, 1993, in which you requested our comments with respect to an RRSP annuitant removing cash from an RRSP by means of a promissory note on the understanding that the note would be repaid within the same taxation year. ...