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Technical Interpretation - External summary
5 January 1993 T.I. 923226 (November 1993 Access Letter, p. 491, ¶C9-290; (Tax Window, No. 28, p. 16, ¶2375) -- summary under Subsection 15(2)
5 January 1993 T.I. 923226 (November 1993 Access Letter, p. 491, ¶C9-290; (Tax Window, No. 28, p. 16, ¶2375)-- summary under Subsection 15(2) Summary Under Tax Topics- Income Tax Act- Section 15- Subsection 15(2) A loan may still qualify after its transfer at fair market value to a related corporation by which the employee is also employed, because the transfer, by itself, will not result in a new loan agreement. ...
Technical Interpretation - External summary
8 January 1993 T.I. 923191 (November 1993 Access Letter, p. 488, ¶C5-223) -- summary under Paragraph 6(1)(a)
8 January 1993 T.I. 923191 (November 1993 Access Letter, p. 488, ¶C5-223)-- summary under Paragraph 6(1)(a) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a) Where an employee is awarded the permanent possession of an item of jewellery, he will be regarded as being the beneficial owner thereof. ...
Technical Interpretation - External summary
10 February 1993 T.I. 921720C (See also 13 January 1993 T.I. 923304) -- summary under Paragraph 12(1)(x)
10 February 1993 T.I. 921720C (See also 13 January 1993 T.I. 923304)-- summary under Paragraph 12(1)(x) Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(1)- Paragraph 12(1)(x) Amounts paid to Atlantic hog farmers were repayable, except that "if certain conditions subsequent are met they may be forgiven". ...
Technical Interpretation - External summary
8 January 1993 T.I. 922776 (November 1993 Access Letter, p. 503, ¶C109-155; Tax Window, No. 28, p. 5, ¶2367) -- summary under Non-Qualifying Real Property
8 January 1993 T.I. 922776 (November 1993 Access Letter, p. 503, ¶C109-155; Tax Window, No. 28, p. 5, ¶2367)-- summary under Non-Qualifying Real Property Summary Under Tax Topics- Income Tax Act- 101-110- Section 110.6- Subsection 110.6(1)- Non-Qualifying Real Property Real property owned equally by two unrelated individuals that is leased by them to a corporation owned equally by them to be used by it in carrying on its active business will not qualify because, in the case of each individual, the shares owned by him will not represent all or substantially all the fair market value of all the issued and outstanding shares of the corporation. ...
Technical Interpretation - External summary
12 January 1993 T.I. 922833 (November 1993 Access Letter, p. 506, ¶C117-208; Tax Window, No. 28, p. 28, ¶2368) -- summary under Total Charitable Gifts
12 January 1993 T.I. 922833 (November 1993 Access Letter, p. 506, ¶C117-208; Tax Window, No. 28, p. 28, ¶2368)-- summary under Total Charitable Gifts Summary Under Tax Topics- Income Tax Act- Section 118.1- Subsection 118.1(1)- Total Charitable Gifts A gift (i.e., a voluntary transfer of property without consideration and without conditions) is considered to occur where an individual has paid more for an annuity purchased from a charity than the total amounts expected to be received as annuity payments. ...
Miscellaneous summary
30 November 1993 Income Tax Severed Letter 9332145 - DPSP Qualified Investments -- summary under Equity Share
30 November 1993 Income Tax Severed Letter 9332145- DPSP Qualified Investments-- summary under Equity Share Summary Under Tax Topics- Income Tax Act- Section 204- Equity Share General discussion. ...
Technical Interpretation - Internal summary
1993 Internal T.I. 7-920752 -- summary under Paragraph 87(2)(a)
1993 Internal T.I. 7-920752-- summary under Paragraph 87(2)(a) Summary Under Tax Topics- Income Tax Act- Section 87- Subsection 87(2)- Paragraph 87(2)(a) The Rulings Directorate no longer is providing relief where taxpayers suffer unpredictable and unfavourable consequences pursuant to s. 87(2)(a). ...
Technical Interpretation - External summary
28 June 1993 T.I. (Tax Window, No. 32, p. 11, ¶2605) -- summary under Subsection 118.1(6)
28 June 1993 T.I. (Tax Window, No. 32, p. 11, ¶2605)-- summary under Subsection 118.1(6) Summary Under Tax Topics- Income Tax Act- Section 118.1- Subsection 118.1(6) The election under s. 118.1(6) is available in respect of the gift of an equitable interest in a trust. ...
Technical Interpretation - External summary
7 May 1993 T.I. (Tax Window, No. 31, p. 7, ¶2514) -- summary under Subsection 16.1(1)
7 May 1993 T.I. (Tax Window, No. 31, p. 7, ¶2514)-- summary under Subsection 16.1(1) Summary Under Tax Topics- Income Tax Act- Section 16.1- Subsection 16.1(1) Re effect of election on availability of investment tax credit. ...
Technical Interpretation - External summary
6 August 1992 T.I. 921792 (April 1993 Access Letter, p. 143, ¶C76-065) -- summary under Subsection 81(2)
6 August 1992 T.I. 921792 (April 1993 Access Letter, p. 143, ¶C76-065)-- summary under Subsection 81(2) Summary Under Tax Topics- Income Tax Act- Section 81- Subsection 81(2) A per diem allowance of $100 would not qualify for exemption. ...