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Miscellaneous severed letter
13 September 1993 Income Tax Severed Letter 9322985 - RCA Letter of Credit
13 September 1993 Income Tax Severed Letter 9322985- RCA Letter of Credit 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. ... Spice (613) 957-8953 Attention: XXXXXXXXXX September 13, 1993 Dear Sirs: Re: Retirement Compensation Arrangements ("RCAs") This is in reply to your letter of August 9, 1993, and further to your letter of June 25, 1993 and our reply thereto of July 28, 1993. ...
Technical Interpretation - External
1993 External T.I. 9329615 F - Canadian Exploration Expenses
1993 External T.I. 9329615 F- Canadian Exploration Expenses Unedited CRA Tags 66.1(6)(a)(iii.1) 932961 XXXXXXXXXX Peter Lee (613) 957-8977 Attention: XXXXXXXXXX October 21, 1993 Dear Sirs: RE: Canadian Exploration Expense- Paragraph 66.1(6)(a) This is in reply to your letter dated October 4, 1993 requesting a technical interpretation of the above-noted provision in the Income Tax Act (the "Act") with respect to certain transactions which XXXXXXXXXX will be undertaking later in 1993 and early 1994. As explained during our October 20, 1993 telephone conversation (XXXXXXXXXX/Chan), assurances regarding the income tax treatment of proposed transactions can only be given in the form of an advance ruling. ...
Miscellaneous severed letter
22 October 1993 Income Tax Severed Letter 9306138 - Prepaid Funeral Sevices
AUTHOR SUBJECT OF CORPORATE CASE FILE October 22, 1993 XXXXXXXXXX Dear XXXXXXXXXX I am writing in reply to your letter of February 19, 1993, addressed to my predecessor, the Honourable Otto Jelinek, concerning pre-arranged funeral agreements. ... It is intended that this legislation be effective for the 1993 taxation year. ... Yours sincerely, Garth Turner Cal Brown 957-2131 930613 October 15, 1993 ...
Miscellaneous severed letter
25 October 1993 Income Tax Severed Letter 9327745 - Repayment of Certain Pensions
Harding (613) 957-8953 October 25, 1993 Dear Sir: Re: Repayment of Pension Income Amounts This is in reply to your letters of September 28 and 29 1993, in which you asked for clarification of the deductibility of your proposed repayment of pension benefits. ... It is our understanding that you wish to make an election in 1993 or a subsequent year, to repay benefits which you received in the years 1989 through 1993 in accordance with one of these provisions and you wish to know the tax consequences of such an election. ... For example, if in 1993, you were to repay $6,000 of your 1989 pension benefits together with $1,000 interest and you also made regular contributions of $3,000 to your current pension plan, you could deduct $500 in 1993 in respect of the repayment ($3,500- $3,000) and carry forward $6,500. ...
Miscellaneous severed letter
26 November 1993 Income Tax Severed Letter 9331525 - NISA
26 November 1993 Income Tax Severed Letter 9331525- NISA Unedited CRA Tags 12 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. ... Davies Chief Policy and Planning NISA Administration Winnipeg, Manitoba 933152 R3C 3A4 November 26, 1993 Dear Mr. ... In 1993, the error was brought to your attention and a corrective adjustment was made. ...
Miscellaneous severed letter
20 April 1993 Income Tax Severed Letter 9310965 - Qualified Investment RRSP
20 April 1993 Income Tax Severed Letter 9310965- Qualified Investment RRSP Unedited CRA Tags 206(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. 5-931096 XXXXXXXXXX Adèle St-Amour (613) 957-8953 Attention: XXXXXXXXXX April 20, 1993 Dear XXXXXXXXXX Re: Qualified investment in self-directed registered retirement savings plan ("RRSP") This is in response to your letter of February 15, 1993, requesting a clarification of our letter of March 19, 1993. ...
Technical Interpretation - External
17 March 1993 External T.I. 9302585 - Coût indique
17 March 1993 External T.I. 9302585- Coût indique Unedited CRA Tags 206(2), 248(1) 5-930258 XXXXXXXXXX M. Shea-DesRosiers (613) 957-8953 A l'attention de XXXXXXXXXX Le 17 mars 1993 Madame, Monsieur, La présente fait suite à votre lettre du 25 janvier 1993 et à votre conversation téléphonique (XXXXXXXXXX/Shea-DesRosiers) du 25 février 1993 concernant le calcul du "coût indiqué" de biens étrangers dans un REER aux fins du paragraphe 206(2) de la Loi de l'impôt sur le revenu (la "Loi"). ...
Technical Interpretation - Internal
2 June 1993 Internal T.I. 9311507 F - Executive Employment Transition Policy Return Allowance
2 June 1993 Internal T.I. 9311507 F- Executive Employment Transition Policy Return Allowance Unedited CRA Tags 56(1)(a)(ii), 248(1) retiring allowance June 2, 1993 Ottawa District Office Head Office P. ... Delorey 957-8953 Attention: Pat Lesperance Client Assistance Executive Employment Transition Policy Lump Sum Financial Settlement This is in reply to your Round Trip Memorandum of April 20, 1993 concerning the tax status of a lump-sum amount that an employee may receive under the Executive Employment Transition Policy. ... The Director of that Division informed us that the lump-sum amount may consist of some or all of the following: Payment in lieu of unfulfilled up to 52 weeks salary surplus period Payment in lieu of foregone up to 15% of salary benefits Payment to compensate for up to 30% of salary pension reduction In our reply of February 23, 1993 to the Management Programs Division, we confirmed that the lump-sum amount would be considered a retiring allowance for the purposes of the Income Tax Act and that the employer may spread the payment of the amount to the employee over an unrestricted period of time. for DirectorFinancial Industries DivisionRulings DirectorateHAA 4749-3 ...
Technical Interpretation - Internal
18 May 1993 Internal T.I. 9312787 F - Part XI Tax
18 May 1993 Internal T.I. 9312787 F- Part XI Tax Unedited CRA Tags 206(2)(a) May 18, 1993 Toronto District Office Head Office Financial Industries Division G. ... Russo Bill C-92 Subparagraph 206(2)(a)(ii) of the Act This is in reply to your facsimile transmission dated May 3, 1993 regarding the amendments to subparagraph 206(2)(a)(ii) in Bill C-92. ... In our view, a share of a Canadian corporation that becomes a non- resident corporation in July 1991 will not be subject to Part XI tax for the months ending after December 20, 1991 until July 1993 by virtue of subparagraph 206(2)(a)(ii) to the extent it is not an amount included under subparagraph 206(2)(a)(i). ...
Technical Interpretation - Internal
21 June 1993 Internal T.I. 9314217 F - XXXXXXXXXX- Charity
21 June 1993 Internal T.I. 9314217 F- XXXXXXXXXX- Charity Unedited CRA Tags 149.1(1) charitable organization CHARITIES DIVISION Business and General DivisionR.A. Davis, Director Attention: Jane Waterfall Registered Charitable Organization This is in reply to your request of May 11, 1993 that we review a submission from XXXXXXXXXX of April 20, 1993 concerning the formation of a joint venture between a newly created distributor corporation (XXXXXXXXXX) and a Trust (the beneficiaries of which are charities) to market XXXXXXXXXX As discussed on May 17, 1993 over the telephone (Thornley/Waterfall), our initial view was that the resources of any charity connected with the arrangement would be used to benefit not only the charity but also the distributor. ...