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Technical Interpretation - Internal

30 March 1993 Internal T.I. 9305077 F - Indians and UIC

30 March 1993 Internal T.I. 9305077 F- Indians and UIC Unedited CRA Tags 81(1)(a) March 30, 1993 HALIFAX DISTRICT OFFICE Business and General Division J.McNeely, Chief of Audit Glen Thornley  (613) 957-2101 Attention:  Don MacDonald XXXXXXXXXX This is in reply to your Round Trip Memorandum of February 10, 1993 concerning the tax status of Unemployment Insurance payments received by the above noted individual. ...
Technical Interpretation - Internal

2 April 1993 Internal T.I. 9305437 F - Indians

2 April 1993 Internal T.I. 9305437 F- Indians Unedited CRA Tags 81 April 2, 1993 Calgary District Office   Business and General Section A. Stubel Murray Brake  C.A.D., Room 250 (613) 952-0243 Attn:  Felicia Tjong XXXXXXXXXX Unemployment Insurance Benefits This is in reply to round trip memorandum of February 12, 1993, requesting our opinion on the taxability of Unemployment Insurance ("UI") benefits received by XXXXXXXXXX in 1988 and 1989. ...
Technical Interpretation - Internal

11 June 1993 Internal T.I. 9312387 F - Agriculture Organization

11 June 1993 Internal T.I. 9312387 F- Agriculture Organization Unedited CRA Tags 149(1)(e), 149(1)(10) CALGARY DISTRICT OFFICE Business and General Division R. ... Broad XXXXXXXXXX This is in reply to your memorandum of April 21, 1993 with enclosed letter of April 16, 1993 from XXXXXXXXXX who are representing the above noted Association which apparently qualifies under paragraph 149(1)(e) as an agriculture organization. ...
Technical Interpretation - Internal

12 July 1993 Internal T.I. 9316337 F - Withdrawal of Undeducted RRSP Premium

12 July 1993 Internal T.I. 9316337 F- Withdrawal of Undeducted RRSP Premium Unedited CRA Tags 146(8.2)   July 12, 1993 Kitchener District Office Head Office Financial Industries Division P. Spice  (613) 957-8953 Client Assistance Attention:  Ms Carol Grieco   Paragraph 146(8.2)(b) of the Income Tax Act This is in reply to your facsimile transmission of June 2, 1993, requesting our interpretation of the above-noted provision. ...
Technical Interpretation - Internal

29 July 1993 Internal T.I. 9320007 F - Investment By Way of Contributed Surplus

29 July 1993 Internal T.I. 9320007 F- Investment By Way of Contributed Surplus Unedited CRA Tags 20(1)(c), 17(1) July 29, 1993 LAVAL DISTRICT OFFICE HEAD OFFICE Basic Files Rulings Directorate   C. Tremblay    (613) 957-2744 Attention:  Noël Frenette   Investment by Way of Contributed Surplus This is in reply to your telephone enquiry of April 20, 1993, regarding the deduction of interest on borrowed funds by XXXXXXXXXX The true purpose for which the borrowed money was used is relevant in determining whether the interest expense will be allowed as a deduction. ...
Technical Interpretation - Internal

16 August 1993 Internal T.I. 9322137 F - Home Buyers' Plan Repayment

16 August 1993 Internal T.I. 9322137 F- Home Buyers' Plan Repayment Unedited CRA Tags 146.01 August 16, 1993 Thunder Bay District Office Head Office Financial Industries Division P. ... Kannegiesser  Home Buyers' Plan This is in reply to your facsimile transmission of July 26, 1993, in which you ask for our opinion concerning the following situation. ...
Technical Interpretation - Internal

15 September 1993 Internal T.I. 9322507 F - Indians - Employment Income Off a Reserve

15 September 1993 Internal T.I. 9322507 F- Indians- Employment Income Off a Reserve Unedited CRA Tags 81(1)(a) LONDON DISTRICT OFFICEBusiness and GeneralW. ... Bonk-Dann Taxation of Status Indians This is in reply to your Round Trip Memorandum of August 3, 1993 and further to our telephone conversation (Thornley\Bonk-Dann) of September 9, 1993 concerning XXXXXXXXXX XXXXXXXXXX In our view, because the only factor connecting XXXXXXXXXX to the reserve is the family residence, his employment is not exempt from taxation pursuant to section 87 of the Indian Act. ...
Technical Interpretation - Internal

13 December 1993 Internal T.I. 9328197 F - Capital v Current Expense

13 December 1993 Internal T.I. 9328197 F- Capital v Current Expense Unedited CRA Tags 20(1)(e) December 13, 1993 XXXXXXXXXX District Office Head Office Client Assistance Rulings Directorate   (613) 957-8953 Capital vs Current Expenditure This is in reply to your memorandum of September 30, 1993, wherein you requested our comments with respect to the classification of certain costs incurred by the company (the"Company") in the following situation: The Company currently operates a car dealership. ...
Technical Interpretation - Internal

1993 Internal T.I. 9331657 F - Indians - Employment Income

1993 Internal T.I. 9331657 F- Indians- Employment Income Unedited CRA Tags 81 January 20, 1994 Ottawa Taxation Centre Head Office Taxpayer Services Rulings Directorate Section 1238-334-1-1 (613) 957-8953 Cathy Sterling Taxation of Employment Income Earned by a Status Indian This is in reply to your Round Trip Memorandum of October 7, 1993 concerning XXXXXXXXXX a status Indian employed by the XXXXXXXXXX According to your memorandum and the letter received from the taxpayer's representative, the taxpayer does not reside on a reserve and her employer is situated off-reserve. ... The Indian Act Exemption for Employment Income Detailed Guidelines which were sent to Taxation Centres, along with a December 20, 1993 Taxation Programs Branch memorandum, will apply for taxation years after 1992. ...
Technical Interpretation - Internal

1993 Internal T.I. 9331947 F - Taxation of Pension Income Received by Indians

1993 Internal T.I. 9331947 F- Taxation of Pension Income Received by Indians Unedited CRA Tags 7 January 7, 1994 Sudbury Tax Centre      Head Office Sherry Drynan       Rulings Directorate     (613) 957-8953 Taxation of Pension Income Received by Indians This is in reply to your Round Trip Memorandum of October 28, 1993 requesting our comments regarding the tax treatment of pension income received by Indians. ... Employment income in such a scenario was never exempt nor do the "Indian Act Exemption for Employment Income Detailed Guidelines" which were issued on December 15, 1993 extend exemption in such circumstances. ...

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