Search - 德国民法典第1993条

22 July 1993 External T.I. 9308035 F- Two Tier Penalty for Source Deductions Unedited CRA Tags 227(8)   XXXXXXXXXX Attention:  XXXXXXXXXX Dear Sirs: RE:  Two Tier Penalty for Failure to Deduct or Withhold We are replying to your letter of March 19, 1993 concerning the application of the second tier penalty under subsection 227(8) of the Income Tax Act (the Act). ...

24 June 1993 External T.I. 9311515 F- Small Business Corporation Unedited CRA Tags 110.6(1) qualified small business corporation share, 248(1) small business corporation XXXXXXXXXX Attention:  XXXXXXXXXX Dear Sirs: RE:  Small Business Corporation This is in reply to your letter of April 15, 1993 wherein you requested a technical interpretation concerning the definition of small business corporation provided by subsection 248(1) of the Income Tax Act ("Act"). ...

31 May 1993 External T.I. 9313565 F- Information Return, Share Consolidation Unedited CRA Tags 230(3) XXXXXXXXXX Attention:  XXXXXXXXXX Dear Sirs: RE:  Subsection 230(3) of the Income Tax Regulations (the "Regulations") This is in reply to your letter of May 4, 1993 wherein you requested our opinion regarding the requirement under subsection 230(3) of the Regulations to file an information return in the following circumstances: A corporation has only one class of common shares issued and outstanding. ...

7 June 1993 External T.I. 9315180 F- Joint Exploration Corporation Unedited CRA Tags 66(15)(i) JOINT EXPLORATION CORPORATION QUESTION 31 The definition of "shareholder corporation" in paragraph 66(15)(i) makes reference to expenses "incurred or to be incurred by the joint exploration corporation" ("JEC"). ... CPTS June 17, 1993 ...

7 June 1993 External T.I. 9315190 F- Joint Exploration Corporation Unedited CRA Tags 59(3.2)(c), 66(10.2)(d), 66(12.6)(e), 66(15) joint exploration corporation   JOINT EXPLORATION CORPORATION QUESTION 33 In the case of flow-through shares, there is a limitation that effectively restricts amounts that may be renounced to the balances of the cumulative resource pools (e.g., paragraph 66(12.6)(e) in the case of Canadian exploration expenses). ... CPTS June 17, 1993 ...

7 June 1993 External T.I. 9315210 F- Joint Exploration Corporation Unedited CRA Tags 66(10.1)(d), 66(10.2)(d), 66(10.3)(d), 66(15) joint exploration corporation, 66(15) shareholder corporation JOINT EXPLORATION CORPORATION QUESTION 35 In the case of flow-through shares, there is a distinction made between the date of filing an election to renounce and the effective date of the renouncement. ... CPTS  June 17, 1993 ...

7 June 1993 External T.I. 9315230 F- Hedging Gains and Losses- Resource Allowance Unedited CRA Tags ITR 1204, 20(1)(v.1) HEDGING GAINS AND LOSSES/ RESOURCE ALLOWANCE QUESTION 41 The Echo Bay case established that commodity hedging gains and losses are to be included in the computation of resource profits. ... CPTS June 17, 1993 ...

23 July 1993 External T.I. 9315615 F- Deferred Salary Leave Plan Unedited CRA Tags ITR 6801(a) XXXXXXXXXX Dear XXXXXXXXXX RE:  Self Funded Leave Arrangements This is in reply to your letter of May 19, 1993, in which you ask whether the six month provision in paragraph 6801(a) of the Income Tax Act Regulations (the "Regulations") applies once the leave of absence has commenced. ...

26 July 1993 External T.I. 9315745 F- Multi-Currency Loans Unedited CRA Tags 212(1)(b)(vii) XXXXXXXXXX Attention:  XXXXXXXXXX Dear Sirs: RE:  Clause 212(1)(b)(vii) We are replying to your letter dated May 27, 1993 concerning the application of clause 212(1)(b)(vii) of the Income Tax Act (the "Act") to situations involving the borrowing of foreign currencies by a Canadian corporation from non-residents. ...

23 July 1993 Income Tax Severed Letter 9317045- Non-capital Loss Unedited CRA Tags 111(8)(b) 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. 5-931704 XXXXXXXXXX Robert Gagnon (613) 957-8953 Attention: XXXXXXXXXX July 23, 1993 Dear Sirs: Re: Paragraph 111(8)(b) of the Act This is in reply to your letter wherein you requested a technical interpretation concerning the application of paragraph 111(8)(b) of the Income Tax Act ("Act"). ...