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Technical Interpretation - Internal summary

4 January 1993 Memorandum 923244 (November 1993 Access Letter, p.505, ¶C117-207) -- summary under Pension Income

4 January 1993 Memorandum 923244 (November 1993 Access Letter, p.505, ¶C117-207)-- summary under Pension Income Summary Under Tax Topics- Income Tax Act- Section 118- Subsection 118(7)- Pension Income Re distinction between annuity income and gain from disposition of an annuity contract. ...
Technical Interpretation - Internal summary

13 January 1993 Memorandum 923695 (November 1993 Access Letter, p. 487, ¶C2-019) -- summary under Paragraph 2(3)(b)

13 January 1993 Memorandum 923695 (November 1993 Access Letter, p. 487, ¶C2-019)-- summary under Paragraph 2(3)(b) Summary Under Tax Topics- Income Tax Act- Section 2- Subsection 2(3)- Paragraph 2(3)(b) Medical services performed in Canada by a non-resident doctor would constitute carrying on business in Canada. ...
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 - Internal summary

10 November 1992 Memorandum 923297 (September 1993 Access Letter, p. 409, ¶20-1159) -- summary under Class 10

10 November 1992 Memorandum 923297 (September 1993 Access Letter, p. 409, ¶20-1159)-- summary under Class 10 Summary Under Tax Topics- Income Tax Regulations- Schedules- Schedule II- Class 10 Re whether a limestone quarry was a mine for purposes of paragraph 10(k). ...
Technical Interpretation - Internal summary

21 July 1992 Memorandum 921671 (March 1993 Access Letter, p. 64, ¶C5-184) -- summary under Paragraph 6(1)(a)

21 July 1992 Memorandum 921671 (March 1993 Access Letter, p. 64, ¶C5-184)-- summary under Paragraph 6(1)(a) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a) A description of a permissible policy for reimbursing employees for moving expenses resulting from the employer's relocation. ...
Technical Interpretation - Internal summary

21 July 1992 Memorandum 921671 (March 1993 Access Letter, p. 64, ¶C5-184) -- summary under Paragraph 6(1)(b)

21 July 1992 Memorandum 921671 (March 1993 Access Letter, p. 64, ¶C5-184)-- summary under Paragraph 6(1)(b) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(b) An allowance paid to employees paid by reference to their increased commuting distance resulting from an employer's relocation would be included in their income. ...
Technical Interpretation - Internal summary

28 July 1992 Memorandum 921859 (April 1993 Access Letter, p. 151, ¶C180-136) -- summary under Payment & Receipt

28 July 1992 Memorandum 921859 (April 1993 Access Letter, p. 151, ¶C180-136)-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt A taxpayer is not considered to have "paid" interest on a loan owing by him to a charitable foundation by virtue only of journal entries being recorded in his ledgers and those of the foundation. ...
Technical Interpretation - Internal summary

28 July 1992 Memorandum 921859 (April 1993 Access Letter, p. 151, ¶C180-136) -- summary under Subsection 189(1)

28 July 1992 Memorandum 921859 (April 1993 Access Letter, p. 151, ¶C180-136)-- summary under Subsection 189(1) Summary Under Tax Topics- Income Tax Act- Section 189- Subsection 189(1) A taxpayer is not considered to have "paid" interest on a loan owing by him to a charitable foundation by virtue only of journal entries being recorded in his ledgers and those of the foundation. ...
Technical Interpretation - Internal summary

17 February 1993 Memorandum 930202 (Tax Window, No. 30, p. 21, ¶2496) -- summary under Subsection 50(1)

17 February 1993 Memorandum 930202 (Tax Window, No. 30, p. 21, ¶2496)-- summary under Subsection 50(1) Summary Under Tax Topics- Income Tax Act- Section 50- Subsection 50(1) The onus is on the taxpayer to establish that there was a debt owing to him, i.e., "a sum payable in respect of a liquidated money demand, recoverable by action". ...
Technical Interpretation - Internal summary

14 December 1993 Memorandum 931814 (C.T.O. "Bad Debt Reduction for Part of a Loan") -- summary under Subparagraph 20(1)(p)(i)

14 December 1993 Memorandum 931814 (C.T.O. "Bad Debt Reduction for Part of a Loan")-- summary under Subparagraph 20(1)(p)(i) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(p)- Subparagraph 20(1)(p)(i) Review of jurisprudence respecting whether a deduction may be taken under s. 20(1)(p) in respect of a partial debt write-down. ...

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