Search - 德国民法典第1993条

Principal Issues: Family allowances payments were received in 1993 although they relate to the 1991 and 1992 taxation years. ... In the situation you asked us to consider, an individual received family allowance benefits in 1993 which relate to the 1991 and 1992 taxation years. ... It is also our view that even though subsections 56(5) to (7) of the Act were repealed for 1993 and subsequent years, family allowance benefits are required to be included in income as long as they relate to taxation years that are prior to 1993. ...

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. ...

(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. ...

23 September 1993 Internal T.I. 9314977 F- Indians and Pension Payments Unedited CRA Tags 81(1)(a) TAXATION CENTRE- SUDBURY Business and General J.A. ... If she worked under similar circumstances during 1983 to 1993 her employment income would have covered by the Indian Remission Order or extended by the new Remission Order until December 31, 1993. Pension payments which are received after 1993 will be exempt from income taxes providing the employment income that gave rise to the pension income was itself exempt. ...

14 December 1993 Internal T.I. 9327077- Contrat verbal — Question de faits Unedited CRA Tags n/a Le 14 décembre 1993 Bureau de district de Laval Bureau principal Section 442-1-1 Direction des décisions   (613) 957-8953 A l'attention de monsieur J.M. Bergeron   7-932707 XXXXXXXXXX La présente fait suite à votre note de service du 16 septembre 1993 et à nos conversations téléphoniques (Bergeron/Desparois) du 6 et 7 décembre 1993 demandant notre opinion relativement à un contrat verbal conclu entre XXXXXXXXXX Nous avons analysé l'ensemble des documents que vous nous avez fournis et nous sommes d'avis que le problème que vous avez soulevé est une question de faits qui relève du domaine de la vérification et ne requiert pas d'interprétation de la Loide l'impôt sur le revenu. Pour cette raison, nous vous avons suggéré lors de notre conversation téléphonique (Bergeron/Desparois) du 7 décembre 1993 de transmettre votre dossier à la Division du soutien technique de la vérification afin d'obtenir leur opinion relativement à ce dossier. ...

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 ...

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). ...

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. ...

9 November 1993 Internal T.I. 9318697 F- Health and Welfare Trusts Unedited CRA Tags 6(1)(a) Edmonton District Taxation Business and General Office Division Mr. ... Manary- Auditor (613) 957-2138 Health and Welfare Trusts This is in reply to your memorandum of June 21, 1993 in which you requested us to review revisions made to the XXXXXXXXXX The revisions were made with respect to comments we set out in a memorandum dated March 10, 1993. ... In item number 5 of our memorandum dated March 10, 1993, we indicated a concern in relation to Article XXXXXXXXXX which provided that the trust may, inter alia, purchase real property. ...

9 June 1993 Internal T.I. 9313217 F- Life Insurance RCA's Unedited CRA Tags 207.6, 207.5, 12(1)(n.3), 20(1)(r) June 9, 1993 Winnipeg Taxation Centre Head Office Financial Industries Division P. Spice  (613) 957-8953 RCA Unit Employer Services Attn:  Ms Carole Roy XXXXXXXXXX Retirement Compensation Arrangement (RCA) Account Nos.: XXXXXXXXXX This is in reply to your round trip memorandum of April 28, 1993, concerning the above-noted subject. You enclosed with your memorandum copies of correspondence received from XXXXXXXXXX dated April 1 and April 7, 1993, and December 3, 1992, and copies of the 1991 T3-RCA Returns for the above-noted accounts. ...