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Miscellaneous severed letter
25 August 1993 Income Tax Severed Letter 9323466 F - R&D—Depenses admissibles et CII
Le 25 août 1993 DIRECTION DE LA VÉRIFICATION DIRECTION DES DÉCISIONS Division des programmes de Division des industries vérification manufacturières, sociétés Section des programmes de et fiducies vérification spécialisée J. Desparois 957-8982 A l'attention de Michel Lefebvre 7-932346 XXXXXXXXXX La présente fait suite à votre note de service du 16 août 1993 demandant nos commentaires sur la note de service du Bureau de district de Montréal du 13 août 1993. ... Il y aura lieu de voir quel est le problème, si problème il y a, à l'égard des dépenses de R&D qui seront réclamées en 1993, 1994, 1995 lors d'une vérification ultérieure. ...
Miscellaneous severed letter
30 September 1993 Income Tax Severed Letter 9309255 - Research Grants Programme
30 September 1993 Income Tax Severed Letter 9309255- Research Grants Programme Unedited CRA Tags 56(1)(o) 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. ... Larochelle (616) 952-1361 September 30, 1993 Dear XXXXXXXXXX Re: Research Grants Programme We are replying to your letter of March 25, 1993 to which you attached a copy of a draft of the XXXXXXXXXX In your correspondence you have asked us to confirm that payments made under the programme would qualify as research grants under subsection 56(1)(o) of the Income Tax Act (the Act). We also refer to our telephone conversation of August 23, 1993 (XXXXXXXXXX /Larochelle) and your facsimile of September 27, 1993. ...
Administrative Letter
19 October 1993 Administrative Letter 9311746 F - Part-Year Resident With Foreign Business Income (7576-7)
19 October 1993 Administrative Letter 9311746 F- Part-Year Resident With Foreign Business Income (7576-7) Unedited CRA Tags 114(a), 128.1, 128.1(4)(b), 48(1), 25 International Tax ProgramsRulings Directorate Directorate Attention: G. Todd Assessment & Enquiries Programs Section 114 of the Act & Foreign Business Income This is in reply to your memorandum of April 16, 1993 concerning an individual who carried on a business in the U.S. before and after the time he emigrated from Canada to the U.S. ... Furthermore, the U.S. business income for the first fiscal period ended February 28, 1993 (i.e. for the period March 1, 1992 to February 28,1993) would not be required to be included in the individual's income under section 115 of the Act for 1993 since that section is only applicable to a business carried on in Canada. ...
Miscellaneous severed letter
10 January 1993 Income Tax Severed Letter 9321447 - Yukon Indians — Lands Set Aside — Moratorium
Peter Garrett of the Department of Indian and Northern Affairs ("DINA") enquired of you on June 18, 1993 as to what you have found out concerning land set aside in the Yukon. ... Garrett's office in response to an enquiry to the Surrey Taxation Centre dated January 19, 1993 which was forwarded to us. ... Alan McDiarmid (Regional Director, Yukon Region, Indian and Inuit Affairs, DINA), who wrote to us on March 1, 1993 and expanded on the concerns raised by Mr. ...
Miscellaneous severed letter
4 March 1993 Income Tax Severed Letter 9303796 - Foreign Tax Credit—Re U. K. Stock Dividends
4 March 1993 Income Tax Severed Letter 9303796- Foreign Tax Credit—Re U. ... March 4, 1993 International Tax Programs Rulings Directorate Directorate K.B. ... Claude Lemelin 930379 Foreign Tax Credit-Stock Dividends This is in reply to your memorandum of February 9, 1993 wherein you requested our comments concerning Article X (Dividends) of the Canada-U.K. ...
Miscellaneous severed letter
7 December 1993 Income Tax Severed Letter 9333665 - Available-for-Use
Tax Executive Institute December 7, 1993 Question No. XXlll AVAILABLE FOR USE RULES A. ... Owing to programming and data translation problems, this new equipment was not utilized until some time later, say June 1993. ... Brake File: 5-932784 Date: November 23, 1993 ...
Miscellaneous severed letter
16 April 1993 Income Tax Severed Letter 9307025 - Rental Use Convert to Principal Residence — Years Available for Designation
16 April 1993 Income Tax Severed Letter 9307025- Rental Use Convert to Principal Residence — Years Available for Designation Unedited CRA Tags 54(g) 45(3) 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. ... Humenuk (613) 957-2134 April 16, 1993 Dear XXXXXXXXXX Re: Principal Residence Designation We are replying to your letter of March 8, 1993 concerning your ability to designate a particular property as your principal residence. ... The relevant facts in your situation are as follows: XXXXXXXXXX You have asked whether you can declare the property to be your principal residence effective for 1993 since the reason you have not yet occupied it is beyond your control. ...
Miscellaneous severed letter
11 May 1993 Income Tax Severed Letter 9306957 - Indians and Treaties
11 May 1993 Income Tax Severed Letter 9306957- Indians and Treaties Unedited CRA Tags 81(1)(a) 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. ... May 11, 1993 EDMONTON DISTRICT OFFICE Business and General E.J. Schermann, Chief of Audit Division Glen Thornley Attention: Ron Quinn, Chief (613) 957-2101 Public Affairs 930695 Status Indians and Reserves This is in reply to your facsimile of March 9, 1993 with enclosed letter from XXXXXXXXXX requests exempt status based on the presumption that Treaty #8 exempts status Indians from taxation under the Income Tax Act. As discussed with you over the telephone (Thornley/Quinn) on March 15, 1993, Indian settlements are not reserves. ...
Technical Interpretation - External
1 June 1993 External T.I. 9307455 F - Salary Deferral Arrange - Share Appreciation Rights
1 June 1993 External T.I. 9307455 F- Salary Deferral Arrange- Share Appreciation Rights Unedited CRA Tags 248(1) Salary deferral arrangement XXXXXXXXXX Attention: XXXXXXXXXX Dear Sir/Madam: This is in reply to your letter of March 15, 1993, and is further to our letter of January 13, 1993 concerning your advance income tax ruling request (3-923684) that was withdrawn as acknowledged in our letter of March 5, 1993. ...
Technical Interpretation - Internal
1993 Internal T.I. 9314957 F - Breach of Contract - RRSP
1993 Internal T.I. 9314957 F- Breach of Contract- RRSP Unedited CRA Tags 204.1(1), 204.2(1) June 14, 1993 Toronto District Office Head Office General Enquiries Division Financial Industries Group Mary Pat Baldwin (613) 957-8953 Attention: Patricia Hicks Subsections 204.1(1) and 204.2(1) of the Income Tax Act This is in reply to your Memorandum of May 13, 1993 requesting an advance income tax ruling on an enquiry received by your office on May 10, 1993. ...