Search - 德国民法典第1993条

1993 Internal T.I. 9332137 F- Farm Support Payments Unedited CRA Tags 12(1)(x) December 17, 1993 Client Assistance Directorate Head Office G. Levesque, Chief Rulings DirectorateOther Returns & Guides Division 957-8953 933213 Treatment of Permanent Cover Program This is in reply to your memorandum of November 4, 1993, referring to a memorandum dated August 13, 1993 dealing with a referral from the Winnipeg D.O. relating to the inclusion in income of payments received by farmers from Agriculture Canada- Prairie Farm Rehabilitation Administration ("PFRA") under the above-noted program. ... You expressed concern that the position set out in our August 13, 1993 memorandum was a change from that taken earlier in the document "TAX STATUS OF FARM SUPPORT PAYMENTS" which you state, "was straight forward with income being taxable under section 12(1)(x) or 80(1)". ...

22 June 1993 Internal T.I. 9312157 F- Transport of a House as a Moving Expense Unedited CRA Tags 62(1)   June 22, 1993 HEAD OFFICE XXXXXXXXXX DISTRICT Personal and General Section OFFICE   Public Affairs   A. Humenuk   (613) 957-2134 Attention:  XXXXXXXXXX Transport of a House as a Moving Expense We are replying to XXXXXXXXXX memorandum of April 23, 1993 concerning the definition of moving expenses as it relates to XXXXXXXXXX A technical review of section 62 of the Act suggests that the cost of moving the house in which a taxpayer lives is not a "moving expense" as defined in subsection 62(3) since the house itself is not a "household effect" described in subsection 62(3) of the Act. ... However, in paragraph 17 of Interpretation Bulletin IT-178R3 "Moving Expenses" dated May 28, 1993, we have taken the position that the cost of moving a mobile home with the household contents therein will be accepted as a moving expense to the extent that the cost does not exceed that of moving the household goods separately. ...

5 August 1993 Internal T.I. 9308627 F- Large Corporation Tax Unedited CRA Tags 181(1), 181.3(1) August 5, 1993 SCARBOROUGH DISTRICT OFFICE HEAD OFFICE D.A. ... Coker  Large File Case Manager XXXXXXXXXX and Part I.3 of the Income Tax Act (the "Act") This is in reply to your memorandum of March 18, 1993 concerning the above noted subject. ... As discussed with you in our telephone conversation of August 4, 1993, it is our view that XXXXXXXXXX would qualify as a financial institution. ...

23 November 1993 Internal T.I. 9331807 F- Sick Leave Benefits Out of Pension Plan Unedited CRA Tags 56(1)(a), 60(j.1), ITR 8503(15) SCARBOROUGH DISTRICT OFFICE HEAD OFFICE G.J. ... Danford (613) 957-8953 BEIA- 451-1-5 933180 XXXXXXXXXX Letter of September 13, 1993 This is in reply to your round trip memorandum of October 27, 1993, in which you asked us to review the above-noted letter and respond to the client's enquiry. ... Enclosed are the original letter and the Routing Slip dated October 13, 1993 from the Winnipeg Taxation Centre. for DirectorFinancial Industries DivisionRulings Directoratec.c.       ...

17 January 1993 Internal T.I. 9336967 F- Indian-Native Fishermen Unedited CRA Tags 81 January 17, 1993 DO/TC Support Services Section HEAD OFFICE R. Cousineau Rulings Directorate Source Deductions Division (613) 957-8953 Native Fisherman This is in reply to your memorandum dated December 17, 1993, requesting our assistance in determining whether certain Unemployment Insurance Benefits (U.I.) received by native fishermen would be exempt from tax. ... As you are aware, U.I. benefits received by Indians are tax exempt if they are based on employment income which itself was exempt, therefore the guidelines issued December 15, 1993 should be applied in determining whether or not the employment income can be connected to a reserve. ...

1993 Internal T.I. 9320147 F- Taxation of Indian Employment Income Unedited CRA Tags 81(1)(a) February 3, 1994 EDMONTON DISTRICT OFFICE Head Office E.J. ... Our Comments: As you are aware, the subject of the Section 87 Indian Act exemption was reviewed by the Department following the Williams decision, the result of which was the publication of guidelines on the subject on December 15, 1993. You likely received a copy of these guidelines which were sent to all District Offices by the Taxation Programs Branch on December 20, 1993. ...

10 March 1993 Internal T.I. 9306367 F- Indians Unedited CRA Tags 81 March 10, 1993 Ottawa District Office   Business and General Division P. ... Murray Brake  2nd Floor (613) 952-0243 XXXXXXXXXX This is in reply to your round trip memorandum of February 26, 1993, wherein you asked for our opinion relating to the taxability of XXXXXXXXXX XXXXXXXXXX is a Status Indian living on a reserve. ...

10 May 1993 Internal T.I. 9312927 F- Retirement Compensation Arrangement Unedited CRA Tags 207.6(2), 248(1) Retirement compensation arrangement May 10, 1993 WINNIPEG TAXATION CENTRE HEAD OFFICE Employer Services Division Financial Industries Division Lynn Ingram, Section Head Adèle St-Amour    (613) 952-1764 Attention:  Carole Roy Retirement Compensation Arrangement ("RCA") This is in response to your referral of January 19, 1993, received from Source Deductions Division on March 4, 1993. ... In a telephone conversation on May 4, 1993, Ms. Ingram asked that we determine who is responsible for filing the various returns requested under the Income Tax Act in the specific case under study. ...

1993 Internal T.I. 9314957 F- Breach of Contract- RRSP Unedited CRA Tags 204.1(1), 204.2(1) June 14, 1993 Toronto District Office  Head Office General Enquiries Division Financial Industries Group Mary Pat Baldwin (613) 957-8953 Attention:  Patricia Hicks Subsections 204.1(1) and 204.2(1) of the Income Tax Act This is in reply to your Memorandum of May 13, 1993 requesting an advance income tax ruling on an enquiry received by your office on May 10, 1993. ...

9 July 1993 Internal T.I. 9317467 F- RETIRING ALLOWANCE Unedited CRA Tags 248(1) 5(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. ... Le 9 juillet 1993 BUREAU DE DISTRICT DE XXXXXXXXXX BUREAU PRINCIPAL Division des industries A l'attention de: XXXXXXXXXX financières Direction des décisions Robert Gagnon (613) 957-8953 7-931746 Paiements par XXXXXXXXXX La présente est en réponse à votre note de service du 7 juin 1993 par laquelle vous nous demandez si des paiements effectués par XXXXXXXXXX sont des allocations de retraite au sens du paragraphe 248(1) de la Loi de l'impôt sur le revenu («Loi») ou du revenu d'emploi en vertu de l'article 5 de la Loi. ... XXXXXXXXXX devront donc inclure dans le calcul de leur revenu l'indemnité qu'elles recevront en 1993. ...