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Miscellaneous severed letter
23 November 1993 Income Tax Severed Letter 9333565 - Accrued Vacation Pay
DRAFT Tax Executive Institute December, 1993 Question No. 15 ACCRUED VACATION PAY—TAXABILITY IN YEAR OF RETIREMENT An employee retires effective December 31, 1993. ... Will RC require an employer to pay a retiring employee the accrued vacation entitlement in the year of retirement (i.e., 1993), thereby being taxable to the employee in 1993? ... Eisner File: 933356 Date: November 23, 1993 ...
Technical Interpretation - External
18 August 1993 External T.I. 9318445 F - Capital Gains - Non-residents Entering Canada
The shares are to be sold, presumably sometime in 1993 but prior to the individual becoming resident in Canada, in the latter part of 1993. ... You opine that an individual would be deemed to be resident throughout the taxation year 1993 where residency takes place anytime before the end of 1993, providing the individual remains resident for all of 1994. ... This would require filing amended 1993 tax returns following December 31, 1994 as they could not initially claim the capital gain deduction when filing their original 1993 tax returns. ...
Technical Interpretation - External
10 June 1993 External T.I. 9313775 F - Foreign Property in RRSP
10 June 1993 External T.I. 9313775 F- Foreign Property in RRSP Unedited CRA Tags 206(2), 248(1) cost amount XXXXXXXXXX Dear XXXXXXXXXX This is in reply to your letter of May 7, 1993 concerning the percentage of foreign property that may be held by a trust governed by a registered retirement savings plan ("RRSP"). ... You intend to make your 1993 contribution to a new self-directed RRSP and transfer the property in your current RRSP to the new RRSP. ... If there were an excess at the end of August 1993 but not at the end of September 1993, no tax would be payable in respect of September, and so on. ...
Miscellaneous severed letter
20 December 1993 Income Tax Severed Letter 9333550 - Insurance Premiums—Benefit Calculation
One dividend of $500,000 is paid in respect of the 1993 policy year of November 1, 1992, to October 31, 1993; the second dividend of $200,000 is paid in respect of the 1994 short policy year of November 1, 1993, to April 1994. ... If so, is the $500,000 excluded from the 1993 or 1994 benefit calculation? ... Szeszycki File: 933355 Date: November 23, 1993 ...
Miscellaneous severed letter
23 December 1993 Income Tax Severed Letter 9337005 - Employment Benefits—Automobiles
XXXXXXXXXX 933700 Attention: XXXXXXXXXX December 23, 1993 Dear Sirs: Re: Proposed Amendment to Automobile Operating Cost Benefit This is in reply to your facsimile memorandum dated December 19, 1993, and our subsequent telephone conversation (Szeszycki/XXXXXXXXXX) of December 22, requesting clarification on the effect of a reimbursement by the employee of operating costs, related to the personal use of an employer-provided automobile, on the calculation of the benefit. As pointed out in our telephone conversation, the reference in your memorandum to a proposed amendment to subsection 6(2.2) of the Income Tax Act (the Act), as had been suggested in the Department of Finance Information release dated March 30, 1993, indicated that you had not been made aware of the subsequent release in August, 1993 in which that draft legislation had been revised. ... Your enquiry remains relevant, however, under the August, 1993 draft legislation. ...
Technical Interpretation - Internal
1993 Internal T.I. 9320287 F - Indians - Employment Income
1993 Internal T.I. 9320287 F- Indians- Employment Income Unedited CRA Tags 80 January 17, 1994 SASKATOON DISTRICT OFFICE Head Office L.H. ... This Remission Order will be extended to the end of 1994 for arrangements entered into before the end of 1993. However, from what was discussed in our September 1, 1993, telephone conversation, it would appear that your client fits within the guidelines that were detailed in the memorandum dated December 20, 1993, to All District Offices/Processing Centres and International Taxation Office. ...
Technical Interpretation - External
1 April 1993 External T.I. 9303695 F - Retroactive Pension Payment
1 April 1993 External T.I. 9303695 F- Retroactive Pension Payment Unedited CRA Tags 56(1)(a)(i) XXXXXXXXXX Dear XXXXXXXXXX This is in reply to your letter of February 1, 1993 concerning a payment to be received by you in 1993 out of XXXXXXXXXX More particularly, you were receiving sickness benefits until XXXXXXXXXX and your application for continuance of salary disability benefits has been refused. The XXXXXXXXXX has a policy that will allow your pension benefits to be paid retroactively from XXXXXXXXXX and you therefore expect to receive in 1993 a lump sum amount representing in part the periodic pension payments that you would have received in 1992. So that you will not be taxed in 1993 on both 1992 and 1993 pension payments, you ask if you can amend your 1992 return to include in your 1992 income the portion of the lump sum amount that relates to that year. ...
Technical Interpretation - Internal
20 October 1993 Internal T.I. 9322877 F - Home Buyers' Income Inclusion
(References to the legislation are to the most recent amendments announced in the Ways and Means Motion of March 24, 1993; a minor amendment announced August 30, 1993 is not relevant to this discussion.) ... August 3, 1993- Contributes $6000.00 to an RRSP. 4. Completes Form T3012A re the July 1, 1992 contribution and withdraws it free of withholding tax. 5. ... Files the 1993 T1 attaching forms T3012A and T746, and (a) claims the 1993 RRSP contribution (b) reports the T3012A withdrawal (c) claims a deduction for the T3012A withdrawal on the T1 as calculated on the T746. ...
Miscellaneous severed letter
16 December 1993 Income Tax Severed Letter 9326185 F - Part I.3 Tax—Long-term Debt
16 December 1993 Income Tax Severed Letter 9326185 F- Part I.3 Tax—Long-term Debt Unedited CRA Tags 181(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. ... JURIDIQUE: Avis du 6 décembre 1993 (dossier 7181\2-001 des services juridiques). ... DOSSIER SUJET: HAA: 5638-3 XXXXXXXXXX 5-932618 A l'attention de XXXXXXXXXX Le 16 décembre 1993 Mesdames, Messieurs, Objet: Demande d'interprétation La présente est en réponse à votre lettre du 14 septembre 1993 par laquelle vous demandez notre interprétation concernant une modification proposée dans l'avant-projet de loi du 30 août 1993 relativement à la définition de passif à long terme prévue au paragraphe 181(1) de la Loi de l'impôt sur le revenu («Loi»). ...
Technical Interpretation - External
3 March 1993 External T.I. 9300185 F - RRSP Home Buyers' Plan
The plan, as originally proposed in the February 25, 1992 budget permitted RRSP withdrawals after February 25, 1992 and before March 2, 1993, for the acquisition of a house after February 25, 1992 and before October 1, 1993. ... However, withdrawals before March 2, 1993 still must be used to acquire a home before October 1, 1993, and one cannot participate in both phases of the plan. ... For those who make their withdrawals after March 1, 1993, they must acquire their house by September 30, 1994. ...