Search - 德国民法典第1993条

14 September 1993 Income Tax Severed Letter 923416A F- Production Sharing Agreement Unedited CRA Tags 126(7) non-business income tax 932242 XXXXXXXXXX Attention:  XXXXXXXXXX Dear Sirs: RE:  Paragraph 126(7)(a) of the Income Tax Act (the "Act") We are writing in reply to your letter dated August 3, 1993, in which you requested we reconsider the comments made in our letter dated July 15, 1993 (the "previous letter") with respect to the issue that the foreign taxes that were described therein are similar to Canadian taxes on the basis that they are very similar to taxes under Part XIII of the Act. ...

13 September 1993 Internal T.I. 9314747 F- Committeeship Fees Unedited CRA Tags 18(1)(a), 20(1)(bb) SURREY TAXATION CENTRE HEAD OFFICE Financial Industries Division G. MartineauTaxpayer Services Attention:  Pam Lyons Committeeship Fees XXXXXXXXXX This is in reply to your memorandum dated May 11, 1993 concerning the deductibility of committeeship fees for the taxpayer mentioned above. ... In his letter dated February 8, 1993, the representative mentioned that the committeeship fees on the taxpayer's estate are health related. ...

9 September 1993 Income Tax Severed Letter 9315025- Deemed Dividend—Stock Divestiture Unedited CRA Tags 90 12(1)(k) ART 13 ART 10 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. ... Middleton (613) 957-2122 Attention: XXXXXXXXXX September 9, 1993 Dear Sir: This is in reply to your letter of May 4, 1993 in which you requested our views on the tax consequences to Canadian resident shareholders in the following circumstances. ...

20 September 1993 Income Tax Severed Letter 9321275- Life Annuities Unedited CRA Tags 70(5.3) 89(1)(b) 245(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. Prenez note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle du ministère. 932127 XXXXXXXXXX Michèle Trotier (613) 957-3494 Attention: XXXXXXXXXX September 20, 1993 Dear Sirs: This is in reply to your letter dated July 21, 1993 wherein you requested our opinion as to what would be the fair market value for purposes of subsection 70(5.3) of the Income Tax Act ("Act") of an annuity owned by a corporation on the life of an individual. ...

30 August 1993 External T.I. 9321505 F- Replacement Property Unedited CRA Tags 44(5)(a)   XXXXXXXXXX Attention:  XXXXXXXXXX Dear Sirs: RE:  Paragraph 44(1)(a) and Subsection 44(5) This is in reply to your letter of July 27, 1993, seeking clarification of the "use test" required by paragraph 44(5)(a) of the Income Tax Act (the "Act"), specifically as it applies to vacant land, in view of the comment in paragraph 15 of Interpretation Bulletin IT-259R2 which indicates that a property that has not been used by a taxpayer to earn income therefrom cannot qualify as property subject to subsection 44(1) of the Act. ... However, we reiterate the comment made in our July 7, 1993 letter to you that vacant land would generally be excluded from the definition of replacement property as non-use does not constitute use. ...

13 September 1993 Income Tax Severed Letter 9324505- Pooled Fund Trust Income Unedited CRA Tags REG 5000(7) 104(6) 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) 957-9853 Attention: XXXXXXXXXX September 13, 1993 Dear Sirs: Re: Regulation 5000(7) of the Income Tax Act (the "Act") This is in reply to your letter and facsimile transmission of May 4, 1993 in which you ask several questions concerning the interpretation of the word "income" in paragraph (b) of the definition of "pooled fund trust" contained in the above-noted Regulation. ...

15 September 1993 External T.I. 9325025 F- Lawyer's Disbursements Unedited CRA Tags 18(1)(a), 34 XXXXXXXXXX Attention:  XXXXXXXXXX Dear Sirs: RE:  Tax Treatment of a Lawyer's Disbursements This is in reply to your facsimile letter of September 2, 1993 asking if the technical interpretation on the above noted subject given in a letter dated March 4, 1986 is still valid. As noted by you in your letter and as discussed (Thornley/XXXXXXXXXX) on September 13, 1993, the answers given in the letter in question were based on Interpretation Bulletin IT-129 and the writer's understanding of the subject. ...

15 September 1993 External T.I. 9316685- Allocation automobile — Auto de l'employeur Unedited CRA Tags 6(1)(b)(vii.1), 18(1)(r)     5-931668 XXXXXXXXXX Carole Chouinard   957-8953 A l'attention de XXXXXXXXXX Le 15 septembre 1993 Monsieur, Objet: Allocation versée à un employé à l'égard d'une automobile La présente fait suite à votre lettre du 28 mai 1993 dans laquelle vous nous demandez notre opinion concernant une allocation versée à un employé à l'égard d'une automobile. ...

28 September 1993 Income Tax Severed Letter 9317095- Refundable ITCs and the Refundable Portion of Part I Taxes Unedited CRA Tags 127.1 129(3) 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. ... Desparois (613) 957-8953 Attention: XXXXXXXXXX September 28, 1993 Dear Sir\Madam: Re: Refundable Investment Tax Credits (RITC) and the Refundable Portion of Part I Taxes This is in reply to your letter dated May 17, 1993 addressed to Mr. ...

22 September 1993 Income Tax Severed Letter 9324715- Retiring Allowance Rollover to an RRSP Unedited CRA Tags 60(j.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. ... Delorey (613) 957-8953 Attention: XXXXXXXXXX September 22, 1993 Dear Sirs: This is in reply to your facsimile transmission of August 30, 1993. ...