Search - 德国民法典第1993条

24 May 1994 External T.I. 9406465- 6363-1 FOREIGN AFFILIATE- DEEMED ACTIVE BUSINESS INCOME-- summary under Paragraph 95(2)(a) (historical) Summary Under Tax Topics- Income Tax Act- Section 95- Paragraph 95(2)(a) (historical) Discussion of the implications of the 22 February 1994 Budget on the factual situation described below in 16 December 1993 T.I. 932563. ...

CRA confirmed this result, and also stated: 1- As the Magdalen Islands were a "prescribed zone" for the taxation years 1988 to 1994; 2- If the individual met all the conditions for the application of section 110.7; and 3- Since the Magdalen Islands have been an "intermediate zone" since the 1988 taxation year; the "specified percentage" for deductions for residents of prescribed zones would be: 100% for taxation years between 1988 and 1992; 66 2/3 % for the 1993 taxation year; and 50% for the 1994 and subsequent taxation years. ...

9 March 1995 External T.I. 9430255- BUTTERFLY REORG- CAPITAL GAINS ELECTION-- summary under Subsection 110.6(7) Summary Under Tax Topics- Income Tax Act- 101-110- Section 110.6- Subsection 110.6(7) Where two shareholders of a CCPC decided, in December 1993, to undertake a butterfly reorganization (which actually was undertaken in August 1994) and the two shareholders filed the capital gains election in respect of their shares, the resulting deemed capital gain could form part of the series of transactions to the same extent as an actual disposition. ...

6 February 2004 External T.I. 2003-0049461E5 F- Parité salariale- Pension rétroactive-- summary under Subparagraph 56(1)(a)(i) Summary Under Tax Topics- Income Tax Act- Section 56- Subsection 56(1)- Paragraph 56(1)(a)- Subparagraph 56(1)(a)(i) retroactive pay-equity increase to the pension receipts of the deceased were s. 56(1)(a)(i) inclusions to the receiving estate An estate received in 2003 an equalization adjustment in respect of superannuation or pension benefits that had been received by an individual under a registered pension plan prior to having died between 1987 to 1993. ...

The Agency indicated that the answer to Q. 36 of the 1993 CTF Roundtable only concerned the repayment of a loan either with the property loaned or with other property. ...

CRA assumed that the wife will designate Immovable2 as her principal residence for the years 1995 to 2006 inclusive (as well as 1992, 1993, and 1994) and that, as a result, the husband must designate the same property for the years 1995 to 2006 – in which case, Immovable1 would be treated as a capital property subject to the change-in-use rules. ...

CRA assumed that the wife will designate Immovable2 as her principal residence for the years 1995 to 2006 inclusive (as well as 1992, 1993, and 1994) and that, as a result, the husband must designate the same property for the years 1995 to 2006 – in which case, Immovable1 would be treated as a capital property subject to the change-in-use rules. ...