Search - 德国民法典第1993条

5 April 1993 Income Tax Severed Letter 9301675- Assets Used in Active Business—Small Business Corporation Unedited CRA Tags 248(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. ... Brooks (613) 957-2103 Attention: XXXXXXXXXX April 5, 1993 Dear Sirs: Re: Small Business Corporations This is in reply to your letter of January 15, 1993 in which you requested our view as to whether a corporate taxpayer would be viewed as a small business corporation within the meaning of subsection 248(1) of the Income Tax Act (the "Act"). ...

2 April 1993 Income Tax Severed Letter 9305845- Employees Profit Sharing Plan Unedited CRA Tags 144(3) 144(6) 6(1)(d) 153(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. Prenez note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle du ministère. 5-930584 XXXXXXXXXX Adèle St-Amour (613) 957-8953 Attention: XXXXXXXXXX April 2, 1993 Dear Sirs: Re: Employees profit sharing plan ("EPSP") This is in reply to your letter of February 19, 1993, in which you ask the opinion of the Department on whether there are withholding tax requirements pursuant to subsection 153(1) of the Income Tax Act (the "Act") on the amounts paid to the employees out of an EPSP. ...

20 April 1993 Internal T.I. 9303437 F- Limitation Regarding Food and Beverages Expenses Unedited CRA Tags 67.1(1)(d), 6(1)(b), 6(6)(a)(ii) April 20, 1993 Winnipeg District Office HEAD OFFICE Business Enquiries Rulings Directorate J.D. ... McDougall Section 67.1 of the Income Tax Act (the "Act") We are writing to you in reply to your memorandum of February 8, 1993 in which you requested our comments on the application on section 67.1 in a factual situation involving XXXXXXXXXX  To briefly summarize the issue, XXXXXXXXXX feels that subparagraph 6(6)(a)(ii) of the Act exempts it from subsection 67.1(1) pursuant to paragraph 67.1(1)(d), whereas Audit staff in the District Office feel that there is no such exemption since the employees are on travel status and their meal allowance is excluded from their income by virtue of paragraph 6(1)(b). ...

16 April 1993 Internal T.I. 9305677 F- Stripped Bonds-Interest Unedited CRA Tags 12(3)   April 16, 1993 Toronto District Office 13 Business and General Section Counter Enquiries Murray Brake    (613) 952-0243 Attn:  D. Russo Interest on Stripped Bonds Sold Before Maturity This is in reply to your fax dated February 23, 1993 concerning the disposition before maturity of two bonds. ...

16 April 1993 External T.I. 9307195 F- Ordering of Non-Capital Losses Unedited CRA Tags 111(1)(b), 111(5), 249(4) XXXXXXXXXX Attention:  XXXXXXXXXX Dear Sirs: RE:  S. 111(1)(b) Ordering of Applied Non-capital Losses This is in reply to your letter of March 5, 1993 requesting that we confirm your understanding of "Revenue Canada's policy with respect to the application of non-capital losses where in a particular year a corporate taxpayer has incurred non-capital losses from carrying on a business as well as from other sources." In particular, you presented a hypothetical scenario, whereby a corporation whose control is acquired during the 1993 fiscal year has both business losses and property losses incurred in its 1992 taxation year. ...

6 May 1993 Income Tax Severed Letter 9301685- Rental Property—Separate Classes Unedited CRA Tags REG 1103(1) REG 1101(1ac) CLASS 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. ... Brooks (613) 957-2103 Attention: XXXXXXXXXX May 6, 1993 Dear Sirs: Re: Subsection 1103(1) of the Income Tax Regulations (the "Regulations") Election to Include Properties in Class 1 This is in reply to your letter of January 14, 1993 in which you requested our view concerning the application in a hypothetical situation of subsection 1103(1) of the Regulations which provides for the inclusion in class 1 of Schedule II of assets otherwise included in classes 2 to 10, 11 and 12 of Schedule II. ...

28 April 1993 Income Tax Severed Letter 9302735- Instalments Unedited CRA Tags 153(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. ... Eisner (613) 957-2138 Attention: XXXXXXXXXX April 28, 1993 Dear Sirs: Re: Quarterly Instalments—Individuals This is in reply to your letter of January 22, 1993 in which you requested our views on whether income taxes can be considered to have been deducted or withheld from certain income for the purposes of subsection 153(2) of the Income Tax Act (the Act). ...

3 May 1993 Internal T.I. 9302747 F- Alimony Maintenance Court Order Written Agreement Unedited CRA Tags 60.1(3), 56.1(3)   May 3, 1993 St. ... Sherman      (613) 957-2136 Acting Assistant Director- Client Services 930274 XXXXXXXXXX-     Subsections 60.1(3) and 56.1(3) We are writing in reply to your memorandum of January 27, 1993, wherein you requested our opinion as to whether or not a Court Order would supersede Minutes of Settlement with respect to the payment of support to a spouse. ...

30 April 1993 External T.I. 9303295 F- RRSP- Investment in U.S. Options Unedited CRA Tags 146(10), 204 qualified investment, ITR 4900(1)(e) XXXXXXXXXX Attention:  XXXXXXXXXX Dear XXXXXXXXXX RE:  Registered Retirement Savings Plan ("RRSP") Investment in U.S. Options This is in response to your letter of January 29, 1993, in which you ask if a call or put option based and traded on the New York Stock Exchange is a qualified investment in a self directed RRSP. ... On February 4, 1993, the Department of Finance released Draft Amendments on qualified investments for deferred income plans. ...

13 May 1993 External T.I. 9313125 F- Depositary Registered Retirement Savings Plan Unedited CRA Tags 146(2)(c.3), 146(13), 146(2)(c.4) XXXXXXXXXX Attention:  XXXXXXXXXX Dear Sir\Madam RE:  Registered Retirement Savings Plan ("RRSP") This is in reply to your letter of February 1, 1993 to our Registered Plans Division that we received on May 5, 1993 for answer. ...