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Administrative Letter

21 September 1993 Administrative Letter 9322566 F - Funding Media of Registered Pension Plan

21 September 1993 Administrative Letter 9322566 F- Funding Media of Registered Pension Plan Unedited CRA Tags ITR 8502(g) Registered Plans Division Financial Industries Division Attention:  Ms Robin Stong Letter of June 7, 1993 from XXXXXXXXXX This is in reply to your memorandum of August 9, 1993, enclosing the above-referenced letter and asking us to respond. ...
Administrative Letter

5 October 1993 Administrative Letter 9327316 F - Letter From ADM Re Taxation of Indian Employment Income

The process of consultation for the development of guidelines referred to in my letter of March 10, 1993 is ongoing but nearing completion. However, the Department has not changed its position, as outlined to you at page 2 of my March 10, 1993 letter, that certain types of income will be exempt. ... Yours sincerely, Denis Lefebvre Assistant Deputy Minister Legislative and Intergovernmental Affairs Branch September 30, 1993 ADM# 931170 ...
Administrative Letter

22 September 1993 Administrative Letter 9327046 F - Business Expense

22 September 1993 Administrative Letter 9327046 F- Business Expense Unedited CRA Tags 18(1)(a) Client Assistance Directorate Financial Industries H.K.Beauchemin Division Director General Attention:  Rick Owen Corporate Deductibility of Costs for Cardio-Pulmonary Resuscitation (CPR) Courses Further to our telephone conversation(Owen/Shea-DesRosiers) of September 21, 1993, concerning our reply of September 13, 1993 to your memorandum of June 9, 1993 on the above-subject (our file 7-931720), we have the following comments in response to your queries: 1.      ...
Administrative Letter

22 September 1993 Administrative Letter 9322776 F - RRSP Advantage - Chance to Win a Prize

22 September 1993 Administrative Letter 9322776 F- RRSP Advantage- Chance to Win a Prize Unedited CRA Tags 146(2)(c.4), 146(13.1) Registered Plans Division Financial Industries S.M. Kotlar, Division Director Attention:  Jeannine Lauzière XXXXXXXXXX This is in reply to your memorandum of June 18, 1993, which was received in this office on August 12, 1993, concerning the RRSP XXXXXXXXXX We have reviewed the material submitted with your memorandum and agree that the opportunity to win a prize by participating in the XXXXXXXXXX is not conditional in any way on the existence of a participant's RRSP. ...
Administrative Letter

19 October 1993 Administrative Letter 9311746 F - Part-Year Resident With Foreign Business Income (7576-7)

19 October 1993 Administrative Letter 9311746 F- Part-Year Resident With Foreign Business Income (7576-7) Unedited CRA Tags 114(a), 128.1, 128.1(4)(b), 48(1), 25 International Tax ProgramsRulings Directorate Directorate Attention:  G. Todd Assessment & Enquiries Programs Section 114 of the Act & Foreign Business Income This is in reply to your memorandum of April 16, 1993 concerning an individual who carried on a business in the U.S. before and after the time he emigrated from Canada to the U.S. ... Furthermore, the U.S. business income for the first fiscal period ended February 28, 1993 (i.e. for the period March 1, 1992 to February 28,1993) would not be required to be included in the individual's income under section 115 of the Act for 1993 since that section is only applicable to a business carried on in Canada. ...
Administrative Letter

30 July 1993 Administrative Letter 9317426 F - Travel Air Miles Given by Employer to Employees

30 July 1993 Administrative Letter 9317426 F- Travel Air Miles Given by Employer to Employees Unedited CRA Tags 6(1)(a) Source Deductions Division Personal and General Section A. ... Support Services Section Travel Miles Program We are replying to your memorandum dated June 10, 1993 concerning a letter you received from XXXXXXXXXX dated May 26, 1993. ...
Administrative Letter

1993 Administrative Letter 9334076 F - Non-Qualified Investments

1993 Administrative Letter 9334076 F- Non-Qualified Investments Unedited CRA Tags 149.1(1) non-qualified investment, 149.1(1)(f), 189(4) December 9, 1993 R.A. DavisBusiness and General Director Division Charities Division 957-8953 Attention: Normand Rocheleau 933407 Subsection 189(4) of the Income Tax Act (the "Act") Computation of interest with respect to a share This is in response to your Memorandum of November 22, 1993, wherein you asked us to review the draft response that you have prepared in regards to a request from the XXXXXXXXXX for confirmation that they "must use the average of prescribed interest rates for the period from date of issue of such shares to date". ...
Administrative Letter

3 September 1993 Administrative Letter 9322766 F - Moving Expenses

3 September 1993 Administrative Letter 9322766 F- Moving Expenses Unedited CRA Tags 62(3)(f) Technical Publications DivisionRulings Directorate J.F. ... Larochelle A/Director Attention:  Milled Azzi Opinion Letter- IT-178R3 Moving Expenses This is in response to your memorandum of August 11, 1993 regarding the enquiry from the firm of XXXXXXXXXX in which they request an interpretation relating to the above interpretation bulletin and, in particular, clarification as to the deductibility of the items described paragraphs 12(f) and 13 of the bulletin. In your proposed reply to XXXXXXXXXX and on which you have requested our comments you have advised him as follows: "This is in reply to your letter dated June 29, 1993, wherein you requested our opinion on whether or not the fee paid by a purchaser to a buyer's agent, in the "Buyer/Agency" concept, would qualify as an eligible moving expense. ...
Administrative Letter

7 June 1993 Administrative Letter 9303236 F - Interest Free Loans Under Dnd Disability Plan

7 June 1993 Administrative Letter 9303236 F- Interest Free Loans Under Dnd Disability Plan Unedited CRA Tags 80.4 A. ... He points to the fact that the employer wishes to avoid a negative financial impact to the employees who received these loans prior to 1993. ... Exhibit 3 of XXXXXXXXXX's May 11, 1993 submission states that the experience refund is calculated, in part, on the expenses of the plan which include the net amount related to the rehabilitation loans. ...
Administrative Letter

22 December 1993 Administrative Letter 9316286 F - Is the Clawback of OAS an Income or Profits Tax (7793-5)

22 December 1993 Administrative Letter 9316286 F- Is the Clawback of OAS an Income or Profits Tax (7793-5) Unedited CRA Tags 180.2, 56(1)(a)(i), 110(1)(f), Article II Provincial and InternationalRulings Directorate Relations Division Attention:  E.E. ... Section 180.2 of the Act provides for a tax ("clawback") of old age security benefits and, for taxation years before 1993, family allowance benefits where the individual's income is in excess of $50,000. Section 180.2 imposes a tax on every individual for each taxation year equal to the lesser of: (a)     the net amount of benefits received under the Old Age Security Act or, for taxation years before 1993, family allowance under the Family Allowances Act, and (b)     15% of net income in excess of $50,000 (indexed after 1988). ...

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