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Technical Interpretation - External summary

11 March 1993 T.I. (Tax Window, No. 30, p. 22, )2495) -- summary under Subsection 118.6(1)

11 March 1993 T.I. (Tax Window, No. 30, p. 22,)2495)-- summary under Subsection 118.6(1) Summary Under Tax Topics- Income Tax Act- Section 118.6- Subsection 118.6(1) Students taking courses provided by the Certified General Accountants Association who are employed in the accounting field will not be entitled to the deduction because of the exception in paragraph (b) of the definition of "qualifying educational program" in s. 118.6(1). ...
Technical Interpretation - External summary

24 March 1992 T.I. (920203 (March 1993 Access Letter, p. 76, ¶C109-126; Tax Window, No. 18, p. 24, ¶1827) -- summary under Property

24 March 1992 T.I. (920203 (March 1993 Access Letter, p. 76, ¶C109-126; Tax Window, No. 18, p. 24, ¶1827)-- summary under Property Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Property A particular covenant that is a restriction against land and which runs with the land and is binding on the landlord and his successors in title, will qualify as property for purposes of s. 248(1). ...
Technical Interpretation - External summary

21 April 1993 T.I. (Tax Window, No. 31, p. 9, ¶2518) -- summary under Subsection 13(27)

21 April 1993 T.I. (Tax Window, No. 31, p. 9, ¶2518)-- summary under Subsection 13(27) Summary Under Tax Topics- Income Tax Act- Section 13- Subsection 13(27) A fishing vessel cannot be considered to be capable of performing the function for which it was acquired until all permits, certificates and licences are acquired. ...
Technical Interpretation - External summary

18 June 1992 T.I. 921747 (January - February 1993 Access Letter, p. 21, ¶C76-062) -- summary under Section 87

18 June 1992 T.I. 921747 (January- February 1993 Access Letter, p. 21, ¶C76-062)-- summary under Section 87 Summary Under Tax Topics- Other Legislation/Constitution- Federal- Indian Act- Section 87 A payment out of an RRSP would not be considered personal property situate on a reserve unless the head office of the financial institution was situate there. ...
Technical Interpretation - External summary

26 February 1993 T.I. (Tax Window, No. 29, p.17, ¶2440) -- summary under Paragraph 12(1)(x)

26 February 1993 T.I. (Tax Window, No. 29, p.17, ¶2440)-- summary under Paragraph 12(1)(x) Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(1)- Paragraph 12(1)(x) A reimbursement or other assistance received in respect of eligible capital property cannot be applied to offset the cost amount of that property and, instead, must be included in income. ...
Technical Interpretation - External summary

28 June 1993 TI (Tax Window, No. 32, p. 10, ¶2604) -- summary under Income-Producing Purpose

28 June 1993 TI (Tax Window, No. 32, p. 10, ¶2604)-- summary under Income-Producing Purpose Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Income-Producing Purpose The costs of acquiring insurance for the indemnification of a director or officer will be deductible where the amount of the premium is reasonable and can be considered instrumental in attracting and retaining qualified personnel. ...
Technical Interpretation - External summary

6 April 1992 T.I. 920399 (March 1993 Access Letter, p. 69, ¶C56-215; Tax Window, No. 18, p. 22, ¶1859) -- summary under Paragraph 56(1)(n)

6 April 1992 T.I. 920399 (March 1993 Access Letter, p. 69, ¶C56-215; Tax Window, No. 18, p. 22, ¶1859)-- summary under Paragraph 56(1)(n) Summary Under Tax Topics- Income Tax Act- Section 56- Subsection 56(1)- Paragraph 56(1)(n) Amounts paid to students under Pacific Rim Educational Initiatives constitute scholarships or bursaries pursuant to s. 56(1)(n). ...
Technical Interpretation - External summary

7 June 1993 T.I. (Tax Window, No. 31, p. 23, ¶2549) -- summary under Allocation in Proportion to Patronage

7 June 1993 T.I. (Tax Window, No. 31, p. 23, ¶2549)-- summary under Allocation in Proportion to Patronage Summary Under Tax Topics- Income Tax Act- Section 135- Subsection 135(4)- Allocation in Proportion to Patronage The payment by a non-profit housing project for seniors of the excess of the selling price for units over the cost of construction would not qualify as a patronage dividend because the housing units would not be "goods or products". ...
Technical Interpretation - External summary

25 August 1992 T.I. 921739 (April 1993 Access Letter, p. 136, ¶C20-1143; Tax Window, No. 23, p. 17, ¶2139) -- summary under Section 34

25 August 1992 T.I. 921739 (April 1993 Access Letter, p. 136, ¶C20-1143; Tax Window, No. 23, p. 17, ¶2139)-- summary under Section 34 Summary Under Tax Topics- Income Tax Act- Section 34 The s. 34 election is not available to a taxpayer who carries on an insolvency practice as his primary practice, rather than as an incidental part of his accounting practice. ...
Technical Interpretation - External summary

16 July 1992 T.I. 921140 (January - February 1993 Access Letter, p. 14, ¶C20-1137) -- summary under Section 76

16 July 1992 T.I. 921140 (January- February 1993 Access Letter, p. 14, ¶C20-1137)-- summary under Section 76 Summary Under Tax Topics- Income Tax Act- Section 76 A cash-basis farmer will have to include the amount of a promissory note, due and payable 30 days after demand, received on the sale of inventory where that security was received in absolute settlement of the debt. ...

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