Search - 德国民法典第1993条

28 May 1993 Ruling 9313173 F- Retiring Allowance Re-employment Unedited CRA Tags 56(1)(a(ii), 248(1) Retiring allowance   XXXXXXXXXX Attention:  XXXXXXXXXX Dear Sirs: RE:  Advance Ruling Request XXXXXXXXXX This is in reply to your letter of May 5, 1993 requesting an advance income tax ruling concerning amounts paid to certain individuals by the XXXXXXXXXX on termination of their employment. ...

22 April 1993 Ruling 9311411 F- Stripped Bonds Unedited CRA Tags 12(4), 12(9), ITR 7000, 20(14)   QUESTION See attached letter from XXXXXXXXXX to XXXXXXXXXX, dated April 8, 1993, concerning the proper taxation of stipped bonds. ...

18 January 1993 Ruling 9231633 F- Golf Course- Non-Profit Organization Unedited CRA Tags 149(1)(l), 149(5)(e)(i), 44   923163 XXXXXXXXXX Glen Thornley   (613) 957-2101 Attention:  XXXXXXXXXX January 18, 1993 Dear Sirs: Re:  XXXXXXXXXX This is in reply to your letter of October 20, 1992 requesting an advance income tax ruling on behalf of XXXXXXXXXX, and further to our telephone conversation (Thornley\XXXXXXXXXX) of November 9, 1992 concerning the ruling request and other related issues. ...

3 May 1993 Ruling 9306443 F- Qualified Farm Property Unedited CRA Tags 110.6(2) XXXXXXXXXX  Attention:  XXXXXXXXXX Dear Sirs: RE:  Family Farm Property This is in reply to your letter of February 23, 1993 in which you requested an advance income tax ruling confirming that the farm property presently held by you and your wife constitutes Qualified Farm Property within the definition contained in subsection 110.6 (1) of the Income Tax Act (the "Act") for purposes of the Enhanced Capital Gains Deduction provided in subsection 110.6 (2) of the Act. ...

27 May 1993 Ruling 9304483 F- Conversion of Use Unedited CRA Tags 45(1)(a) XXXXXXXXXX Attention:  XXXXXXXXXX Dear Sirs: RE:  Deemed Disposition Rules- Conversion of Use This is in reply to your letter of February 8, 1993 concerning the application of subsection 45(1) of the Income Tax Act (the "Act") as it applies to a taxpayer who constructed a property for sale, but instead leased the property for one year and immediately thereafter, used the property as his personal residence. ...

29 June 1993 Ruling 9307413 F- CONVENTION FISCAL CANADA-ÉTATS-UNIS Unedited CRA Tags 212(1)b) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... Séguin (613) 957-8953 A l'attention de XXXXXXXXXX Le 29 juin 1993, Monsieur, La présente est en réponse à une lettre en date du 9 décembre 1992 dans laquelle votre représentant XXXXXXXXXX nous demandait une opinion concernant l'application de la Convention Canada-États-Unis (la "Convention) en relation avec les dispositions de l'alinéa 212(1)b) de la Loi de l'impôt sur le revenu (la "Loi"). ...

11 May 1993 Ruling 9310751 F- Large Corporations Tax- Meaning of Reserves Unedited CRA Tags 181(1), 37(1)(b), 127(5), 127(9) SR&ED qualified expenditure tool HAA 5638-3 PRINCIPAL ISSUES For purposes of Part I.3, do a corporation's reserves, as defined in 181(1), include:-     the capital portion of scientific research and experimental development expenditures which have been incurred but which have not been deducted under 37(1)(b); and-     unclaimed investment tax credit (under 127(5)) in respect of such expenditures? ...

19 March 1993 Ruling 9307673 F- Commutation of Annuity Contracts Unedited CRA Tags 56(1)(d)   XXXXXXXXXX  Attention:  XXXXXXXXXX Dear Sirs: RE:  Structured Settlements This is in reply to your recent letter received in this office on March 17, 1993 concerning the commutation of annuity contracts purchased by an insurer to fund its liability under a "structured settlement" as contemplated in Interpretation Bulletin IT-365R2. ...

17 May 1993 Ruling 9310171 F- Insurance Policies and Policy Loans Unedited CRA Tags 148(2), 148(9) policy loan, 148(9) cash surrender value The Conference for Advanced Life Underwriting 1993 Annual Conference Officer's Analysis Question #3 It is our understanding that policy dividends which are left on deposit with the insurer belong to the insured and can generally be withdrawn by the policyholder at any time. ...

16 June 1993 Ruling 9309871 F- Meaning of All or Substantially All Unedited CRA Tags 181(1), ITR 8604(a), 190(1) HAA 5638-2 PRINCIPAL ISSUE Parts I.3 and VI of the Act both include definitions for "financial institution" which definitions include a reference to "a corporation all or substantially all of the assets of which are shares or indebtedness of corporations described in... to which the corporation is related" (subsection 181(1) of the Act and paragraph 8604(a) of draft Income Tax Regulations in the case of Part I.3, and subsection 190(1) of the Act in the case of Part VI)). ...