Search - 德国民法典第1993条

7 June 1993 External T.I. 9315170 F- Joint Exploration Corporation Unedited CRA Tags 66(10), 66(15) shareholder corporation, 66(15) joint exploration corporation JOINT EXPLORATION CORPORATION QUESTION 30 Does a shareholder corporation within the meaning of the expression under paragraph 66(15)(i) of the Act ("Shareholder Corp") have to be a shareholder of a joint exploration corporation ("JEC") at the date when renouncements are made by the JEC under subsections 66(10) to (10.3) of the Act, or is it sufficient that the Shareholder Corp be a shareholder of the JEC at the date that the expenses being renounced are incurred? ... CPTS June 17, 1993 ...

29 July 1993 External T.I. 9318875 F- Capitalization of Interest Unedited CRA Tags 21(1) XXXXXXXXXX Attention:  XXXXXXXXXX Dear Sirs: RE:  Capitalization of Interest We are writing in response to your letter of June 29, 1993 in which you requested our opinion with respect to the application of subsection 21(1) of the Income Tax Act (Canada)(the "Act"). ...

20 August 1993 External T.I. 9314425 F- The Time the Partnership is Formed Unedited CRA Tags 96(1) XXXXXXXXXX  Attention:  XXXXXXXXXX Dear Sirs: This is in reply to your letter dated May 13, 1993 requesting a technical interpretation as to the tax consequences of transferring property to a limited partnership that has not yet commenced operating its business. ...

1 September 1993 External T.I. 9315945 F- Expropriation Princ. Res. Unedited CRA Tags 44(2)(b), 40(2)(b) XXXXXXXXXX  Attention:  XXXXXXXXXX Dear Sirs: RE:  Expropriations and Principal Residence Exemptions- Subsection 44(2) and Paragraph 40(2)(b) of the Income Tax Act (the "Act") This is in reply to your letter of May 28, 1993 concerning the above- mentioned subject. ...

24 August 1993 Internal T.I. 9319087 F- Mortgages- Investments for RPP Unedited CRA Tags ITR 8514(2)(e)(iii) Registered Plans Division Financial Industries S.M. ... Lalonde Employee Mortgages as Investments for a Registered Pension Plan ("RPP") and reasonable rate of interest of mortgages- XXXXXXXXXX This is in reply to your memorandum of June 29, 1993 concerning a request by the XXXXXXXXXX for the application of subparagraph 8514(2)(e)(iii) of the Regulations. ...

31 August 1993 Internal T.I. 9324627 F- Part XI Tax, Penalty or Tax Unedited CRA Tags 206(2), 220(3.1) Calgary District Office Head Office Client Assistance Financial Industries Division Attention:  Linda McGuire Part XI tax; your file 8994 803 This is in response to your letter of August 23, 1993, requesting our opinion whether tax assessed under Part XI of the Income Tax Act is considered to be a penalty for purposes of subsection 220(3.1). ...

17 September 1993 External T.I. 9317955 F- Business Expense Unedited CRA Tags 18(1)(A) XXXXXXXXXX Dear Madam: This is further to your letter of May 18, 1993 which was forwarded to us by the Winnipeg District Office for reply. ...

8 September 1993 External T.I. 9310075 F- Testamentary Trust Unedited CRA Tags 108(1) testamentary trust   XXXXXXXXXX  Attention:  XXXXXXXXXX Dear Sirs: RE:  Testamentary Trust We are writing in response to your letter of April 1, 1993, in which you requested an interpretation of paragraph 108(1)(i) of the Income Tax Act (the "Act"). ...

27 September 1993 External T.I. 9315535 F- Director's Fees Unedited CRA Tags 9(1) XXXXXXXXXX Attention:  XXXXXXXXXX Dear Sir\Madam: RE:  Director's Fees This is in reply to your letter dated May 18, 1993 concerning the nature of the income received by a corporation where such corporation earns director's fees as discussed in paragraph 4 of Interpretation Bulletin IT-377R. ...

14 June 1993 External T.I. 9317470 F- Interest Expense- Accounts Payable Unedited CRA Tags 20(1)(c)   1993 CANADIAN PETROLEUM TAX SOCIEY ROUND TABLE INTEREST EXPENSE QUESTION 36 Interest is deductible pursuant to 20(1)(c)(ii) in respect of an amount payable for property related to a business. 20(1)(c)(ii) is presumably considered necessary by the Department of Finance on the grounds that an unpaid purchase price is not "borrowed money", so that any interest charged by suppliers on overdue accounts would not be deductible, but for 20(1)(c)(ii). ...