Search - 德国民法典第1993条

29 June 1993 External T.I. 9305565 F- Employee Incentive Awards Unedited CRA Tags 6(1)(a) XXXXXXXXXX Attention:  XXXXXXXXXX Dear Sir: RE:  Employee Service Awards This is in reply to your letters of February 18, 1993 and May 10, 1993 which are further to our letter of January 8, 1993 sent to your company. ... In our letter of January 8, 1993, we provided general comments in which we indicated that an employee is considered to have received a taxable benefit where his or her employer provides him or her with a long term service award of jewellery and the employee acquires ownership of the jewellery at that time. ...

6 August 1993 External T.I. 9320095 F- Change Fiscal Period Unedited CRA Tags 248(1) fiscal period XXXXXXXXXX Dear Sir: RE:  Change of fiscal period This is in reply to your letter of July 6, 1993 and is further to our reply of June 15, 1993 to your letter of April 29, 1993. You wish to find out if, in the situation outlined in your letter of April 29, 1993, there will be a termination of the taxpayer's first legal practice in one city with a resultant year end at the termination date and whether the start up of the same practice in another city will result in a new year end. ...

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. ...

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"). ...

22 June 1993 External T.I. 9308855 F- Advance Ruling Unedited CRA Tags 18(1)(a)   XXXXXXXXXX Dear Sir: This is further to our telephone conversation (Fontaine/XXXXXXXXXX) of April 8, 1993 in which you undertook to provide additional facts that would clarify your particular concerns regarding a proposed agreement with the XXXXXXXXXX A copy of the agreement was forwarded to us by the Ottawa District Office on March 25, 1993. ... Accordingly, if we do not receive the necessary information by July 16, 1993, we will conclude that you do not wish to proceed with this matter and our file will be closed. ...

17 August 1993 External T.I. 9308845 F- Exempt Property of the Specified Property Rules Unedited CRA Tags ITR 1100(1.13)(a)(ii) XXXXXXXXXX Attention:  XXXXXXXXXX Dear Sirs: RE:  "Exempt Property" of the "specified Leasing Property Rules" This is in reply to your letter of March 22, 1993 wherein you requested clarification of our technical interpretation dated March 9, 1993. ...

27 September 1993 External T.I. 9327175 F- Personal Services Business Unedited CRA Tags 18(1)(p) XXXXXXXXXX  Attention:  XXXXXXXXXX Dear Sirs: RE:  Personal Services Business This is to confirm that the opinion expressed in our letter of January 19, 1993 (file no. 5-922987) is correct. The answer given to question 3C of the 1993 Revenue Canada Round Table with the Manitoba Bar Association and Institute of Chartered Accountants of Manitoba no longer reflects the Department's position concerning the application of paragraph 18(1)(p) of the Income Tax Act. ...

23 November 1993 External T.I. 9330535 F- RRSP- Qualified Investment- Golf Membership Unedited CRA Tags 146(1) qualified investment, 204 qualified investment, ITR 4900 XXXXXXXXXX Dear Sir/Madam: This is in reply to your undated letter, received in this office on October 25, 1993, asking if a membership in the XXXXXXXXXX is a qualified investment for a registered retirement savings plan ("RRSP"). As discussed during our (XXXXXXXXXX/Delorey) telephone conversation on November 15, 1993, a membership in a golf club is not a qualified investment for an RRSP. ...

2 September 1993 External T.I. 9324005 F- Taxable Benefit Plans- Purchase of Vacation Leave Unedited CRA Tags 6(1)(a)   XXXXXXXXXX  Attention:  XXXXXXXXXX Dear Sirs: RE:  Tax Treatment of Vacation in lieu of Salary This is in reply to your letter of August 20, 1993 in which you requested our views as to the tax implications of purchasing additional vacation leave in lieu of a salary increase. ... In the example contained in your letter, an employee receiving a base salary of $40,000 in 1992 elects before September of that year to use his salary increase for 1993 of 4% ($1,600) to purchase an additional two weeks vacation. Although the employee's base salary has risen to $41,600 for the purpose of future pay raise calculations, he will only be taxed on the $40,000 in 1993. ...

1993 External T.I. 9335545 F- Sub — 256(2) and T2144 Unedited CRA Tags 256(2) 5-933554 XXXXXXXXXX Attention:  XXXXXXXXXX December 10, 1993 Dear Sir: RE:  Subsection 256(2) and Form T2144 We are writing in response to your letter of November 29, 1993 in which you have requested clarification of the Department's position concerning the election (Form T2144) available under subsection 256(2) of the Income Tax Act. ... Comments A directive signed by the Director of Audit Programs Division (Jean- Pierre Lavigne) was sent to all District Offices on October 21, 1993 advising that late-filed elections under subsection 256(2) on prescribed Form T2144 can now be accepted under certain conditions. ... Tim Bryant December 10, 1993 ...