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Technical Interpretation - External summary
4 March 1993 T.I. (Tax Window, No. 30, p. 14, ¶2475) -- summary under Section 87
4 March 1993 T.I. (Tax Window, No. 30, p. 14, ¶2475)-- summary under Section 87 Summary Under Tax Topics- Other Legislation/Constitution- Federal- Indian Act- Section 87 Unemployment insurance benefits received in respect of employment income exempt from taxation are also so exempt. ...
Technical Interpretation - External summary
24 March 1993 T.I. (Tax Window, No. 38, p. 1, ¶2490) -- summary under Subsection 246(1)
24 March 1993 T.I. (Tax Window, No. 38, p. 1, ¶2490)-- summary under Subsection 246(1) Summary Under Tax Topics- Income Tax Act- Section 246- Subsection 246(1) Re potential application of s. 246(1) to a holder of common shares where his father exchanges preferred shares of the corporation for preferred shares having a lower redemption amount and for options. ...
Technical Interpretation - External summary
3 December 1993 T.I. 920099 [no discount for future taxes] -- summary under Shares
3 December 1993 T.I. 920099 [no discount for future taxes]-- summary under Shares Summary Under Tax Topics- General Concepts- Fair Market Value- Shares no discount for future taxes "The value of property relates to the attributes of the property itself and is unaffected by the tax position. ...
Technical Interpretation - External summary
16 March 1993 T.I. (Tax Window, No. 30, p. 15, ¶2478) -- summary under Subparagraph 212(1)(d)(ii)
16 March 1993 T.I. (Tax Window, No. 30, p. 15, ¶2478)-- summary under Subparagraph 212(1)(d)(ii) Summary Under Tax Topics- Income Tax Act- Section 212- Subsection 212(1)- Paragraph 212(1)(d)- Subparagraph 212(1)(d)(ii) The provision by a non-resident engineering company of the conclusions of its research by means of a training course given outside Canada to Canadian-resident engineers for a fixed registration fee, would not be subject to 212(1)(d)(ii). ...
Technical Interpretation - External summary
19 June 1992 T.I. 9218450 (January - February 1993 Access Letter, p. 20, ¶C56-212) -- summary under Subsection 75(2)
19 June 1992 T.I. 9218450 (January- February 1993 Access Letter, p. 20, ¶C56-212)-- summary under Subsection 75(2) Summary Under Tax Topics- Income Tax Act- Section 75- Subsection 75(2) S.75(2) can apply by virtue of a right of the contributor of property to reacquire that property at fair market value. ...
Technical Interpretation - External summary
16 March 1993 T.I. (Tax Window, No. 30, p. 15, ¶2478) -- summary under Article 7
16 March 1993 T.I. (Tax Window, No. 30, p. 15, ¶2478)-- summary under Article 7 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 7 Payment to a U.S. ...
Technical Interpretation - External summary
2 April 1993 T.I. (Tax Window, No. 30, p. 8, ¶2486) -- summary under Section 67
2 April 1993 T.I. (Tax Window, No. 30, p. 8, ¶2486)-- summary under Section 67 Summary Under Tax Topics- Income Tax Act- Section 67 Re deductibility of bonus paid by Opco for management services of its holding company provided by the only shareholder of the holding company, and of a similar bonus paid by the holding company to that shareholder. ...
Technical Interpretation - External summary
26 November 1992 T.I. 923059 (September 1993 Access Letter, p. 422, ¶C144-237) -- summary under Subsection 4900(4)
26 November 1992 T.I. 923059 (September 1993 Access Letter, p. 422, ¶C144-237)-- summary under Subsection 4900(4) Summary Under Tax Topics- Income Tax Regulations- Regulation 4900- Subsection 4900(4) An investment of an RRSP in a fund that invested only in mortgages, where there was no evidence that the fund would hold the mortgages as nominee or agent for the RRSP, would not be a qualified investment. ...
Technical Interpretation - External summary
16 March 1993 T.I. (Tax Window, No. 30, p. 21, ¶2505) -- summary under Subsection 402(3)
16 March 1993 T.I. (Tax Window, No. 30, p. 21, ¶2505)-- summary under Subsection 402(3) Summary Under Tax Topics- Income Tax Regulations- Regulation 402- Subsection 402(3) A capital gain from the disposition of property would not be included in a taxpayer's "gross revenue" whose definition in s. 248(1) specifically excludes amounts as or on account of capital. ...
Technical Interpretation - External summary
21 June 1993 T.I. (Tax Window, No. 32, p. 8, ¶2600) -- summary under Eligible Real Property Gain
21 June 1993 T.I. (Tax Window, No. 32, p. 8, ¶2600)-- summary under Eligible Real Property Gain Summary Under Tax Topics- Income Tax Act- 101-110- Section 110.6- Subsection 110.6(1)- Eligible Real Property Gain Re whether property last acquired by an individual after February 1992 from the individual's spouse will give rise to an eligible real property gain. ...