Search - 德国民法典第1993条

25 October 1993 Income Tax Severed Letter 9324605- Foreclosure Action Instituted by Mortgagee Unedited CRA Tags 116(5.3) 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. ... Patrick (613) 957-2125 Attention: XXXXXXXXXX October 25, 1993 Dear Madam: Re: Interpretation of subsection 116(5.3) This is in reply to your letter of August 26, 1993, concerning our interpretation of 116(5.3) of the Income Tax Act (the "Act") as it applies to a mortgagee instituting a foreclosure action in various jurisdictions in Canada operating under different land registration systems. ...

22 November 1993 External T.I. 9329245 F- NISA- Farm Support Payments Unedited CRA Tags 12(10.2), 248   XXXXXXXXXX   Attention:  XXXXXXXXXX Dear Sirs: RE:  AGR-1 Information Slip Initiative This is in reply to your letter of October 5, 1993 in which your outline the details of the Agricultural Land Development Act (ALDA) program. ... As discussed with you (Thornley\XXXXXXXXXX) on November 19, 1993, the Department's position with respect to less than market interest being charged on loans under various Agriculture Canada programs is set out in a publication entitled "Status of Farm Payments" which is available from Agriculture Canada. ...

13 December 1993 Internal T.I. 9328197 F- Capital v Current Expense Unedited CRA Tags 20(1)(e) December 13, 1993 XXXXXXXXXX District Office Head Office Client Assistance Rulings Directorate   (613) 957-8953 Capital vs Current Expenditure This is in reply to your memorandum of September 30, 1993, wherein you requested our comments with respect to the classification of certain costs incurred by the company (the"Company") in the following situation: The Company currently operates a car dealership. ...

1993 Administrative Letter 9334076 F- Non-Qualified Investments Unedited CRA Tags 149.1(1) non-qualified investment, 149.1(1)(f), 189(4) December 9, 1993 R.A. DavisBusiness and General Director Division Charities Division 957-8953 Attention: Normand Rocheleau 933407 Subsection 189(4) of the Income Tax Act (the "Act") Computation of interest with respect to a share This is in response to your Memorandum of November 22, 1993, wherein you asked us to review the draft response that you have prepared in regards to a request from the XXXXXXXXXX for confirmation that they "must use the average of prescribed interest rates for the period from date of issue of such shares to date". ...

1993 External T.I. 9335495 F- Interest in a Bond as Qualified Investment for RRSP Unedited CRA Tags 146(1) qualified investment, ITR 4900(1)(i) PRINCIPAL ISSUES: Whether an "interest" in a bond is a qualified investment for an RRSP. ... LEGAL: N/A FINANCE OPINION: N/A JURISPRUDENCE: N/A RCT PUBLICATIONS: N/A HAA NUMBER: 7255-7 933549 XXXXXXXXXX Attention:  XXXXXXXXXX December 21, 1993 Dear Sirs: RE:  Qualified Investment This is in reply to your facsimile transmission of December 3, 1993, in which you ask whether an interest in a global bond would be a qualified investment for a registered retirement savings plan (RRSP). ...

1993 External T.I. 9314180 F- 5870 Treaty Shopping and GAAR Unedited CRA Tags 245 1993 CORPORATE TAX MANAGEMENT CONFERENCE QUESTION 7 THE GENERAL ANTI-AVOIDANCE RULE Does Revenue Canada believe that "treaty shopping" is subject to the general anti-avoidance rule. ... Prepared by: Olli Laurikainen Date: November 23, 1993 File No: 931418 ...

1993 External T.I. 9314620 F- U.S. Limited Liability Companies (HAA 4093-U5-100-4) Unedited CRA Tags 95(1) foreign affiliate, 248(1) corporation, Treaty US Article IV CORPORATE MANAGEMENT TAX CONFERENCEROUND TABLEJUNE 1993 Characterization of Foreign Entities Question 12 It is possible in certain U.S. states to incorporate a U.S. limited liability company. ... Wilson Date: May 19, 1993 (Control #931462) ...

1993 External T.I. 9315720 F- Corporation Continuing Into Foreign Jurisdiction 7576-3 Unedited CRA Tags 250(5.1), 250(5), Treaty US Article IV   1993 CORPORATE MANAGEMENT TAX CONFERENCE CANADIAN CORPORATION CONTINUING IN A FOREIGN JURISDICTION Under proposed subsection 250(5.1) of the draft technical amendments released December 21, 1992 (the "draft amendments"), if a company incorporated in Canada is granted articles of continuance in another jurisdiction, the corporation is deemed to have been incorporated in the other jurisdiction and not to have been incorporated in Canada. ... Prepared by: Olli Laurikainen Date: November 23, 1993 File: 931572 ...

20 December 1993 Income Tax Severed Letter 9318775- No- or Low-Interest Loan Unedited CRA Tags 105(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. ... XXXXXXXXXX 931877 Attention: XXXXXXXXXX December 20, 1993 Dear Sirs: Re: Subsection 105(1) of the Income Tax Act (the "Act") This is in reply to your letter of June 23, 1993 concerning subsection 105(1) of the Act and loans made by a non-resident trust to Canadian beneficiaries thereof to acquire a house in Canada. ...

1993 External T.I. 9331455 F- Contract Payments from Foreign Source Unedited CRA Tags 37(1)(a), 127(9) contract payment, 127(11.1) 5-933145 XXXXXXXXXX C. ... Brown (613)      957-8953 Attention:  XXXXXXXXXX November 5, 1993 Dear Sirs: RE:  Scientific Research and Experimental Development (SR & ED)- Treatment of Contract Payments This is in reply to your letter dated October 21, 1993 wherein you requested our opinion as to whether a payment made by a particular foreign entity, that is not subject to tax in Canada, in respect of SR & ED expenditures incurred by a Canadian corporation ("Canco") would be considered as a contract payment for purposes of computing Canco's investment tax credit pursuant to paragraph 127(11.1) of the Income Tax Act (the "Act"). ...