Search - 德国民法典第1993条

1993 Internal T.I. 9312947 F- Dual Residency and the Tie-Breaker Rule (4093-C8-100) Unedited CRA Tags Treaty Czechoslovakia Article 4, Treaty Czechoslovakia Article 13 May 6, 1993 Carole Gouin-ToussaintRulings Directorate Director General Attention:  E. Makheil Canada-Czechoslovakia lncome Tax Convention (the "Convention") This is in response to your verbal request that we review the letter dated May 4, 1993 to XXXXXXXXXX Paragraph 3, Page 2. ...

28 June 1993 Internal T.I. 9315847 F- Small Business ITC Unedited CRA Tags 127(9), REG 4602 June 28, 1993 TORONTO DISTRICT OFFICE Manufacturing Industries, Partnerships and Trusts DivisionPierre St. Laurent  Assistant Director- Audit  XXXXXXXXXX Small Business Investment Tax Credit This is in reply to your memorandum of May 27, 1993 requesting that we review material concerning the new Small Business Investment Tax Credit (the "SBITC"). ...

1993 Internal T.I. 9334247 F- Discounted Debt Obligations Unedited CRA Tags 12(9), 12(3), 16(1), ITR 7000 PRINCIPAL ISSUES: Application of interest accrual rules pre Reg 7000 POSITION TAKEN: See letter REASONS FOR POSITION TAKEN: See Letter LEGAL: Verbal only FINANCE OPINION: N/A JURISPRUDENCE: See file back-up RCT PUBLICATIONS: See file back-up HAA NUMBER: January 5, 1994 North York District Office Head Office Industry Specialist Section Rulings Directorate (613) 957-8953 Attn: D.W. Mitchell Banking Specialist 933424 Interest Accrual Rules- XXXXXXXXXX This is in reply to your memorandum of November 21, 1993, in which you requested clarification of our views concerning the proper income tax treatment of a non-interest bearing US debt obligation purchased by the above noted taxpayer. ... As indicated in our earlier memorandum dated April 23, 1993, this particular debt obligation was a prescribed debt obligation pursuant to Regulation 7000(1)(a) for taxation years commencing after 1981. ...

4 June 1993 Internal T.I. 9306657 F- Wrongful Dismissal Followed by Reinstatement Unedited CRA Tags 5(1), 248(1) retiring allowance June 4, 1993 Source Deductions Division Rulings Directorate A.W. ... Hammond D.O Support Services Section Wrongful Dismissal Followed by Reinstatement This is in response to your memorandum of March 4, 1993 and further to our telephone conversation of May 12, 1993 (Hammond/Larochelle) regarding the enquiry from the XXXXXXXXXX District Office concerning the tax treatment to be accorded amounts received by an unnamed taxpayer, as the result of an action for wrongful dismissal. ...

17 May 1993 Internal T.I. 9311537 F- Alberta Pension Split on Marriage Breakdown Unedited CRA Tags 56(1)(a) May 17, 1993 HEAD OFFICE EDMONTON Personal and General Enquiries and DISTRICT OFFICE Office Examination Section Taxpayer Requests   A. Humenuk    (613) 957-2134 Attention:  Bryant Town Pension Splitting on the Breakdown of Marriage We are replying to your memorandum of April 15, 1993 concerning the reporting of the pension income received by XXXXXXXXXX Reference is also made to our telephone conversations of April 26 and May 11, 1993 (Town/Humenuk). ...

2 June 1993 Internal T.I. 9306787- Recherche scientifique Unedited CRA Tags ITR 2900(2)(b), 2900(2)(c), 2902(a), 2900(3) Le 2 juin 1993 BUREAU DE DISTRICT DE MONTRÉAL BUREAU PRINCIPAL A l'attention de Direction des décisions M. Richard Bernier Michel Lambert Section 198-2-5 (613) 957-8953   7-930678 XXXXXXXXXX Recherches scientifiques et  développement expérimental La présente fait suite à votre note de service du 28 janvier 1993 concernant le sujet ci-dessus mentionné. ... Michel Lefebvre de cette direction vous a fait parvenir des commentaires le 3 mars 1993. ...

It is anticipated that the aggregate taxable income of J Ltd., D Ltd., A Ltd. and B Ltd. will exceed $200,000 in 1993. ... Our Comments: It would appear that the taxpayers are concerned that the application of section 256 in the 1993 taxation year to the corporate structure described above would, pursuant to subsection 125(3) of the Act, require two or more of A Ltd., B Ltd., J Ltd., and D Ltd. to allocate the business limit of $200,000 referred to in subsection 125(2) of the Act between them in order to claim a small business deduction under subsection 125(1) of the Act. Since the allocation would only appear to be required in the 1993 taxation year of each of the corporations referred to herein, our comments are restricted to the association rules as they would apply in that year. ...

16 June 1993 Internal T.I. 9313917 F- Principal Residence Exemption Unedited CRA Tags 54 principal residence Toronto District Office Business and General Mr. ... We also note that in paragraph 21 of IT-120R4 dated March 26, 1993, the Department has clarified its position in that regard by stating the following: "Other factors which may in some cases be relevant in determining whether land in excess of 1/2 hectare is necessary for the use and enjoyment of the housing unit as a residence are severance or subdivision restrictions and minimum lot sizes (see 22 below). ... Aside from the point that the severance restrictions in the case at hand may not, as indicated above, be related to the size of lot that can be used for residential purposes, the Department is in the process of considering whether to seek leave to appeal the Augart decision to the Supreme Court of Canada which needs to be done by September 23, 1993. ...

28 October 1993 Internal T.I. 9312237 F- Attribution and Alimony Made in Respect of Children Unedited CRA Tags 60(b), 60(c), 74.1(2) Ottawa District Office Business and General Mr. ... Allard, Chief Division Client Assistance Child Support Payments Pursuant to our telephone conversation on September 13, 1993 (M. ... As the information in the attached letter suggests that a marriage breakdown occurred prior to 1993, our comments are so based. ...

1993 Internal T.I. 9302687 F- Indians- Employment Income Unedited CRA Tags 81(1)(a) March 29, 1993 CALGARY DISTRICT OFFICE Business and General Division G.C. ...