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Technical Interpretation - External
9 June 1993 External T.I. 9315240 F - Site Restoration
9 June 1993 External T.I. 9315240 F- Site Restoration Unedited CRA Tags 9 SITE RESTORATION QUESTION 42 Where a taxpayer incurs site restoration costs to return land used as a service station site to its original condition, what is Revenue Canada's view of the income tax treatment of these expenditures? ... CPTS June 17, 1993 ...
Technical Interpretation - External
30 March 1993 External T.I. 9303540 F - Contractor Income
30 March 1993 External T.I. 9303540 F- Contractor Income Unedited CRA Tags 9, 12(1)(a), 20(1)(m) 1993 EDMONTON DISTRICT OFFICE INFORMATION SESSION RE: Contractor QUESTION #1 A Canadian company (Canco) obtains contracts for the sale of large turbines and compressors. ...
Technical Interpretation - External
30 June 1993 External T.I. 9317695 F - Deferred Salary Leave Plan (DSLP)
30 June 1993 External T.I. 9317695 F- Deferred Salary Leave Plan (DSLP) Unedited CRA Tags ITR 6801(a)(iv) XXXXXXXXXX Attention: XXXXXXXXXX Dear Sirs: RE: Deferred Salary Leave Plan (DSLP) This is in reply to your facsimile of April 29, 1993 sent to the London District Taxation Office which was forwarded to this Directorate, requesting a technical interpretation with respect to the XXXXXXXXXX DSLP. ...
Technical Interpretation - External
7 June 1993 External T.I. 9315170 F - Joint Exploration Corporation
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 ...
Technical Interpretation - External
29 July 1993 External T.I. 9318875 F - Capitalization of Interest
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"). ...
Ministerial Correspondence
23 August 1993 Ministerial Correspondence 9315854 F - Golf Course Constr. Costs
23 August 1993 Ministerial Correspondence 9315854 F- Golf Course Constr. ... XXXXXXXXXX Dear XXXXXXXXXX I am writing in reply to your letter of April 22, 1993, addressed to my predecessor, the Honourable Otto Jelinek, regarding the treatment under the Income Tax Act of costs relating to building a golf course. ...
Technical Interpretation - External
18 October 1993 External T.I. 9325725 F - RRIF Minimum Amount in Kind
18 October 1993 External T.I. 9325725 F- RRIF Minimum Amount in Kind Unedited CRA Tags 146.3(1) registered retirement income fund, 146.3(1) minimum amount XXXXXXXXXX Dear Sir: RE: Registered Retirement Income Fund (RRIF) This is in reply to your letter of September 9, 1993, in which you ask whether the "minimum amount" under a RRIF may be paid in a form other than cash. ...
Technical Interpretation - External
17 May 1993 External T.I. 9310160 F - Insurance Policy and Fair Market Value of Shares - CALU
17 May 1993 External T.I. 9310160 F- Insurance Policy and Fair Market Value of Shares- CALU Unedited CRA Tags 104(4), 70(5.3) THE CONFERENCE FOR ADVANCED LIFE UNDERWRITING 1993 Annual Conference Question 2 A spousal trust owns shares of a corporation that owns an insurance policy on the life of the spouse. ...
Miscellaneous severed letter
2 January 1993 Income Tax Severed Letter 9332165 - Interest Deductibility
2 January 1993 Income Tax Severed Letter 9332165- Interest Deductibility Unedited CRA Tags 20(1)(c) 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 933216 Attention:XXXXXXXXXX January 21, 1994 Dear Sirs: This is with respect to your November 1, 1993 letter to us concerning interest deductibility. ...
Technical Interpretation - External
31 May 1993 External T.I. 9315680 F - Thin Capitalization
31 May 1993 External T.I. 9315680 F- Thin Capitalization Unedited CRA Tags 18(4), 18(5)(a) CORPORATE MANAGEMENT TAX CONFERENCEJUNE 1993 ROUND TABLE Outstanding Debts to Specified Non-Residents Question Where a debt owing to a specified non-resident shareholder provides for the annual payment of interest, and interest will accrue (from the due date) on any interest not paid by the annual due date, is the accrued interest on the debt prior to its annual due date an "outstanding debt to specified non-residents" for purposes of subsections 18(4), (5) and (6)? ...