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Technical Interpretation - Internal

10 March 1993 Internal T.I. 9304327 F - Indians - Training Allowances

10 March 1993 Internal T.I. 9304327 F- Indians- Training Allowances Unedited CRA Tags 81(1)(a) March 10, 1993 SASKATOON DISTRICT OFFICE Business & General Division R. Bromley Glen Thornley  (613) 957-2101 Source Deductions  Training Allowances et al- Status Indians This is in reply to your Fax of February 10, 1993 asking that we advise if training allowances, living away from home allowances, travel allowances and dependant allowances, paid to status Indians by CEIC under a program for XXXXXXXXXX are taxable or non-taxable when received. ...
Technical Interpretation - Internal

22 April 1993 Internal T.I. 9310987 F - Deferred Salary Leave Plan

22 April 1993 Internal T.I. 9310987 F- Deferred Salary Leave Plan Unedited CRA Tags ITR 6801 April 22, 1993 North York District Office Head Office Client Assistance Financial Industries  Division   D. Duff  (613) 957-8953 Attention:  Kate Ho XXXXXXXXXX Deferred Salary Leave Plan ("DSLP"): This is in reply to your correspondence forwarded by facsimile on April 15, 1993, regarding the DSLP of the aforementioned client. ...
Technical Interpretation - Internal

31 March 1993 Internal T.I. 9307337 F - Rent Free

31 March 1993 Internal T.I. 9307337 F- Rent Free Unedited CRA Tags 12(1)(x), 9 March 31, 1993 CALGARY DISTRICT OFFICE HEAD OFFICE LARGE CASE FILES  Rulings Directorate   C. ... Bhaloo, Chief Landlord and Tenants- Rent Free Periods XXXXXXXXXX We are writing in response to your memorandum of March 5, 1993, seeking our views with regards to which years our rent free period position should be applied. ...
Technical Interpretation - Internal

15 July 1993 Internal T.I. 9303367 F - Community Futures Self Employment Initiative

15 July 1993 Internal T.I. 9303367 F- Community Futures Self Employment Initiative Unedited CRA Tags 9(1)15, 56(1)(a)(iv) July 15, 1993 SURREY TAXATION CENTRE HEAD OFFICE Personal and General Taxpayer Services Division Section 1233 334-33 A. Humenuk (613) 957-2134 Attention:  Pam Lyons XXXXXXXXXX Self Employment Assistance Program We are replying to your memorandum of January 28, 1993 concerning the above noted taxpayer and the amounts he received from Employment and Immigration Canada under the Self Employment Incentive Program (SEI). ...
Technical Interpretation - Internal

1993 Internal T.I. 9319857 F - Italian Pension - Whether Make Up Payment is Periodic

1993 Internal T.I. 9319857 F- Italian Pension- Whether Make Up Payment is Periodic Unedited CRA Tags 60(j) July 20, 1993 HAMILTON DISTRICT OFFICE HEAD OFFICE A. ... Delorey  (613) 957-8953 Attention:  Thomas Koval  Client Services XXXXXXXXXX Italian Pension Payment of Accrued Pension This is in reply to your FAX transmission of July 7, 1993 concerning a payment of $ XXXXXXXXXX from an Italian pension plan. ...
Technical Interpretation - Internal

1993 Internal T.I. 9330307 F - Trust Allocation of Income

1993 Internal T.I. 9330307 F- Trust Allocation of Income Unedited CRA Tags 104(19), 104(12) December 9, 1993 Vancouver District Office Head Office K.F. Slawson Rulings DirectorateChief of Audit (613) 957-8953 Attention:Ted Fitz-Clarke 933030 Meeting with XXXXXXXXXX We are writing in response to your request of October 20, 1993 in which you asked us to respond to a question submitted by the XXXXXXXXXX The issue required additional consideration with the result that we could not meet your deadline. ...
Technical Interpretation - Internal

1993 Internal T.I. 9311837 F - Indian Exemption

1993 Internal T.I. 9311837 F- Indian Exemption Unedited CRA Tags 81(1)(a) January 11, 1994 Saint John District Office Head Office   Rulings Division   (613)  957-8953 Attention:  Beth Roy XXXXXXXXXX Exemption Under The Indian Act This is in reply to your round trip memorandum of April 19, 1993, wherein you asked whether employment income of an Indian living on a reserve and performing duties off reserve as a school teacher XXXXXXXXXX Facts: XXXXXXXXXX XXXXXXXXXX Our Comments: In the 1991 year employment income was exempt if the employer was resident on the reserve or the employee worked on the reserve. ... As you may be aware, the 'Indian Act Exemption for Employment Income Detailed Guidelines' were issued by the Department on December 15, 1993 in response to the Williams decision (92 DTC 6320) and are relevant for taxation years after 1991. ...
Technical Interpretation - Internal

23 December 1993 Internal T.I. 9335957 F - Overseas Employment Tax Credit-Subcontractor (7070-7)

23 December 1993 Internal T.I. 9335957 F- Overseas Employment Tax Credit-Subcontractor (7070-7) Unedited CRA Tags 122.3(1)(b)(i), 122.3 December 23, 1993 Edmonton District Office Head Office Source Deductions Rulings Directorate   (613)  957-8953 Attention:  D. Hamel Overseas Employment Tax Credit ("OETC") This is in reply to your memorandum of November 15, 1993 in which you asked us to confirm the Department's position with respect to Keith Harding's Decision Summary of November 17, 1992. ...
Technical Interpretation - Internal

24 August 1993 Internal T.I. 9319087 F - Mortgages - Investments for RPP

24 August 1993 Internal T.I. 9319087 F- Mortgages- Investments for RPP Unedited CRA Tags ITR 8514(2)(e)(iii) Registered Plans Division Financial Industries S.M. ... Lalonde Employee Mortgages as Investments for a Registered Pension Plan ("RPP") and reasonable rate of interest of mortgages- XXXXXXXXXX This is in reply to your memorandum of June 29, 1993 concerning a request by the XXXXXXXXXX for the application of subparagraph 8514(2)(e)(iii) of the Regulations. ...
Technical Interpretation - Internal

31 August 1993 Internal T.I. 9324627 F - Part XI Tax, Penalty or Tax

31 August 1993 Internal T.I. 9324627 F- Part XI Tax, Penalty or Tax Unedited CRA Tags 206(2), 220(3.1) Calgary District Office Head Office Client Assistance Financial Industries Division Attention:  Linda McGuire Part XI tax; your file 8994 803 This is in response to your letter of August 23, 1993, requesting our opinion whether tax assessed under Part XI of the Income Tax Act is considered to be a penalty for purposes of subsection 220(3.1). ...

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