Search - 德国民法典第1993条

15 January 1993 T.I. 923421 (November 1993 Access Letter, p. 508, ¶C180-152)-- summary under Article 22 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 22 Discussion of annual distributions of income by a Canadian- resident trust to a U.S. partnership. ...

13 January 1993 T.I. 922909 (November 1993 Access Letter, p. 496, ¶C38-180)-- summary under Paragraph 55(3)(b) Summary Under Tax Topics- Income Tax Act- Section 55- Subsection 55(3)- Paragraph 55(3)(b) Discussion of availability of exemption, and of meaning of "reorganization", where a corporation transfers its shares of a wholly-owned subsidiary ("Subco") to two newly incorporated subsidiary corporations, and Subco then transfers to each of the newly incorporated subsidiaries their pro-rata share of the property of Subco. ...

13 January 1993 T.I. 923208 (November 1993 Access Letter, p. 505; Tax Window, No. 28, p. 15, ¶2382)-- summary under Investment Income Summary Under Tax Topics- Income Tax Act- 101-110- Section 110.6- Subsection 110.6(1)- Investment Income A guarantee fee ordinarily will be considered to be business income rather than investment income. ...

15 January 1993 T.I. 923421 (November 1993 Access Letter, p. 508, ¶C180-152)-- summary under Article 21 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 21 Re taxation of a U.S. charitable organization's share of dividends received by a U.S. partnership from a Canadian resident corporation. ...

13 January 1993 T.I. 922191 (November 1993 Access Letter, p. 500, ¶C76-077)-- summary under Subsection 80.4(1) Summary Under Tax Topics- Income Tax Act- Section 80.4- Subsection 80.4(1) Where a loan is received by an employee of a corporation who owns all its shares, RC will consider that the loan was not contracted qua employee, except under exceptional circumstances. ...

13 January 1993 T.I. 923286 (November 1993 Access Letter, p. 508, ¶C180-151)-- summary under Qualified Investment Summary Under Tax Topics- Income Tax Act- Section 146- Subsection 146(1)- Qualified Investment The delisting of a share, the suspension of its trading or the bankruptcy of the corporation generally will not cause the share to cease to be a qualified investment. ...

26 January 1993 T.I. 923284 (November 1993 Access Letter, p. 512, ¶C245-051; Tax Window, No. 28, p. 1, ¶2383)-- summary under Paragraph 69(1)(b) Summary Under Tax Topics- Income Tax Act- Section 69- Subsection 69(1)- Paragraph 69(1)(b) S.69(1)(b) does not apply to the provision of services for less than their fair market value. ...

13 January 1993 T.I. 923826 (November 1993 Access Letter, p. 508, ¶C180-151)-- summary under Subsection 207.1(1) Summary Under Tax Topics- Income Tax Act- Section 207.1- Subsection 207.1(1) When a public corporation is wound up, a share of the corporation cannot be removed from an RRSP's records and should be valued at its cost amount until such time as it is disposed of. ...

12 January 1993 T.I. 923151 (November 1993 Access Letter, p. 503, ¶C109-154)-- 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 The use of the word "principally" requires that the property as a whole be considered rather than a percentage or a portion of the property. ...

12 January 1993 T.I. 922257 (November 1993 Access Letter, p. 495, ¶C38-178; (Tax Window, No. 28, p. 11, ¶2363)-- summary under Subsection 85(4) Summary Under Tax Topics- Income Tax Act- Section 85- Subsection 85(4) A foreign exchange loss realized under s. 39(2) on the repayment of a U.S. ...