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Conference
7 October 1994 APFF Roundtable Q. 2, 5M08340 - APFF 1994
ROUND TABLE ON FEDERAL TAXATION APFF- 1994 ANNUAL MEETING Question 10 Opinions Issued by Revenue Canada During the 1993 APFF meeting, it was mentioned that district taxation offices may give opinions on specific questions. ... The Queen (1993 DTC 965), the taking over by a supplier of a taxpayer's debt to a third party was considered a payment received by the taxpayer to induce him to purchase the supplier's products. ... ROUND TABLE ON FEDERAL TAXATION APFF- 1994 ANNUAL MEETING Question 44 Permanent Establishment In a technical interpretation issued by the Reorganizations and Foreign Division on 28 June 1993, Revenue Canada states the view that the sales force of a corporation resident in a country may be a permanent establishment in another country within the meaning of the Canada-US tax convention regardless of whether or not the sales persons are empowered to bind the corporation. ...
Conference
20 January 1997 CTF Roundtable Q. 1, 9604996 - : Article XXIX B of Canada-U.S. Treaty
With respect to deaths occurring after November 10, 1988 but before November 10, 1995:- where on November 9, 1995 the last return has not been filed, the claim could be made on filing or within the normal reassessment period for that return;- where on November 9, 1995 the last return has been filed but not yet assessed, the claim could be made prior to the file being assessed or within the normal reassessment period of that return;- where on November 9, 1995 the last return has been filed and assessed, the claim must be made on or before the later of November 9, 1996 and the date on which the normal reassessment period expires;- where the last return was initially assessed on or before November 9, 1993, the claim for the refund must be filed on or before November 9, 1996; and- where the last return was initially assessed after November 9, 1993, the claim must be filed within the normal reassessment period for that return. ... Gardner, "Cross-Border Dimensions of Estate and Trust Planning: A US Perspective", 1993 Canadian Tax Foundation Conference Report, 39:1- 39:15 6. Bender's Master Federal Tax Handbook, "Estate and Gift Taxes", 1993 Edition APPENDIX D Information Required to Process Canadian Tax Credit General Information Required for Every Claimant of Canadian Tax Credit for U.S. ...
Conference
11 October 1996 APFF Roundtable Q. 5, 7M12920 F - TABLE RONDE APFF
La MMNT examinée par l'OCDE diffère des versions américaines de 1992 et 1993 de la marge du bénéfice comparable (MBC). En 1993, le règlement américain a été modifié, mais surtout dans sa forme. ... Le Canada a annoncé officiellement en juillet 1993 le lancement de son programme d'EAPT. ...
Conference
11 October 1996 APFF Roundtable, 7M12910 - APFF ROUND TABLE
The TNM studied by the OECD differs from the 1992 and 1993 American versions of comparable margin of profit (CMP). In 1993, the American regulation was amended, primarily as to form. Our comments on the 1992 version of the regulation, and those of other partners in a convention with the United States and the OECD, were essentially the same as the comments on the 1992 version of the regulation. ... In July of 1993, Canada officially announced the launching of its APA program. ...
Conference
12 April 1994 IFA Roundtable Q. 11, 4M00680 - HALIFAX ROUND TABLE QUESTIONS
Department's position EFILE went very well for tax preparers in Nova Scotia during the 1993 program. ...