Search - 德国民法典第1993条

7 June 1993 Ruling 9315191 F- Joint Exploration Corporation Unedited CRA Tags 59(3.2)(c), 66(10), 66(12.6)(e), 66(10.2)(d), 66(15) joint exploration corporation Issue Sheet 1993 CPTS Roundtable  June 17, 1993 RE:  Joint Exploration Corporation No Balance in Resource Pools Renouncement of Resource Expenses Question #33 In the case of flow-through shares, there is a limitation that effectively restricts amounts that may be renounced to the balances of the cumulative resource pools (e.g., paragraph 66(12.6)(e) in the case of Canadian exploration expenses). ...

7 June 1993 External T.I. 9315220 F- Deductibility of Penalties and Interest on Taxes Unedited CRA Tags 9, 18(1)(a), 18(1)(m), 14(5) eligible capital expenditure, 40(1)   DEDUCTIBILITY OF PENALTIES AND INTEREST ON OTHER TAXES QUESTION 40 Are fines, penalties and interest levied under the Excise Tax Act, the various provincial sales tax statutes, the various provincial capital tax statutes, the various provincial payroll tax statutes, and similar legislation deductible for income tax purposes? DEPARTMENT'S POSITION The Department's general position with respect to fines and penalties is stated in paragraph 2 of Interpretation Bulletin IT-104R2 dated May 28, 1993 as follows: Judicial and statutory fines or penalties do not generally qualify as a deduction in computing income from a business or property under paragraph 18(1)(a), or as an eligible capital expenditure as defined in paragraph 14(5)(b) or as an outlay or expense for the purpose of making a disposition of capital property under subsection 40(1). ... CPTS June 17, 1993 ...

17 June 1993 Income Tax Severed Letter 9316940- Tax Shelter Unedited CRA Tags 237.1 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. ... C.Bowen June 10, 1993 931694 CPTS June 17, 1993 ...

23 July 1993 Income Tax Severed Letter 9320235- Employer Purchase of Past Pension Unedited CRA Tags 6(1)(a) 8(1)(m) 147.2(1) 147.2(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. ... Spice (613) 957-8953 Attention: XXXXXXXXXX July 23, 1993 Dear Sirs: Re: Employer Purchase of Pre-1990 Past Service Pension Benefits This is in reply to your facsimile transmission of July 16, 1993, in which you ask whether an employer contribution to a registered pension plan will be considered a taxable benefit to the employee or if it would be excluded pursuant to paragraph 6(1)(a) of the Income Tax Act (the "Act"). ...

1993 Internal T.I. 9319857 F- Italian Pension- Whether Make Up Payment is Periodic Unedited CRA Tags 60(j) July 20, 1993 HAMILTON DISTRICT OFFICE HEAD OFFICE A. ... Delorey  (613) 957-8953 Attention:  Thomas Koval  Client Services XXXXXXXXXX Italian Pension Payment of Accrued Pension This is in reply to your FAX transmission of July 7, 1993 concerning a payment of $ XXXXXXXXXX from an Italian pension plan. ...

26 July 1993 Ministerial Letter 9319018 F- IT-372R Paragraph 4 Canadian Residence Unedited CRA Tags 212(1) DM'S OFFICE (2) M93-3845T ADM'S OFFICE (3) RETURN TO RULINGS, ROOM 303, MET. ... XXXXXXXXXX Dear XXXXXXXXXX The Honourable Otto Jelinek, former Minister of National Revenue, has asked me to respond to your letter of June 9, 1993, concerning the position expressed in paragraph 4 of Interpretation Bulletin IT-372R, and the Department's opinion as expressed in the letter of May 18, 1993. ...

18 August 1993 External T.I. 9320305 F- Foreign Property- RRIF Unedited CRA Tags 146.3, 206(1) cost amount, 206(2) XXXXXXXXXX Dear XXXXXXXXXX This is in reply to your enquiry of June 30, 1993, concerning the foreign property rules applicable to a self-directed registered retirement income fund ("RRIF"). The 18% (for 1993) maximum foreign property rule applies to each RRIF. ...

1 September 1993 Income Tax Severed Letter 9316695- Forgiveness of Loans Unedited CRA Tags 6(1)(a) 6(15) 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 September 1, 1993 Dear Sir: Re: Subsection 6(15) and paragraph 6(1)(a) of the Income Tax Act (the "Act") This is in reply to your letter of June 1, 1993 wherein you requested our opinion regarding the income tax implications for an employee of a forgiveness of a loan by his/her employer as to whether an amount must be included in his/her income on account of the forgiveness of such a loan. ...

27 August 1993 Income Tax Severed Letter 9324265- Small Business Development Bonds Unedited CRA Tags 15.1 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. ... Tremblay (613) 957-8953 Attention: XXXXXXXXXX August 27, 1993 Dear Sirs: Re: Small Business Development Bonds ("SBDBs") We are writing in response to your facsimile letter dated August 25, 1993, concerning a proposed issue of a SBDB. ...

3 September 1993 Administrative Letter 9322766 F- Moving Expenses Unedited CRA Tags 62(3)(f) Technical Publications DivisionRulings Directorate J.F. ... Larochelle A/Director Attention:  Milled Azzi Opinion Letter- IT-178R3 Moving Expenses This is in response to your memorandum of August 11, 1993 regarding the enquiry from the firm of XXXXXXXXXX in which they request an interpretation relating to the above interpretation bulletin and, in particular, clarification as to the deductibility of the items described paragraphs 12(f) and 13 of the bulletin. In your proposed reply to XXXXXXXXXX and on which you have requested our comments you have advised him as follows: "This is in reply to your letter dated June 29, 1993, wherein you requested our opinion on whether or not the fee paid by a purchaser to a buyer's agent, in the "Buyer/Agency" concept, would qualify as an eligible moving expense. ...