Search - 德国民法典第1993条

21 July 1992 Memorandum 921453 (January- February 1993 Access Letter, p. 34, ¶C144-197)-- summary under Subsection 100(4) Summary Under Tax Topics- Income Tax Regulations- Regulation 100- Subsection 100(4) An establishment of an employer would have many of the same characteristics as that of a permanent establishment, as defined in Regulation 400(2). ...

22 July 1992 Memorandum 921698 (March 1993 Access Letter, p. 81, ¶C144-202)-- summary under Subsection 8507(2) Summary Under Tax Topics- Income Tax Regulations- Regulation 8507- Subsection 8507(2) A legislatively imposed wage freeze generally effects a permanent wage adjustment rather than a temporary wage reduction and, consequently, does not fall within the purview of Regulation 8507. ...

1993 Internal T.I. 9325537 F- Election Under Sub-- summary under Ownership Summary Under Tax Topics- General Concepts- Ownership Discussion of when shares are capital property of the estate as opposed to the beneficiaries, including a finding that a flow-through of dividends to beneficiaries does not demonstrate that the beneficiaries had beneficial ownership of the shares. ...

1993 Internal T.I. 9325537 F- Election Under Sub-- summary under Subsection 164(6) Summary Under Tax Topics- Income Tax Act- Section 164- Subsection 164(6) Discussion of when shares are capital property of the estate as opposed to the beneficiaries, including a finding that a flow-through of dividends to beneficiaries does not demonstrate that the beneficiaries had beneficial ownership of the shares. ...

25 September 1992 Memorandum 922730 (September 1993 Access Letter, p. 416, ¶C76-074)-- summary under Section 87 Summary Under Tax Topics- Other Legislation/Constitution- Federal- Indian Act- Section 87 Interest on a bank account is earned at the location where the funds are on deposit. ...

18 November 1992 Memorandum 921979 (December 1993 Access Letter, p. 407, ¶C9-286)-- summary under Incurring of Expense Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Incurring of Expense A reserve for vacation pay benefits earned by employees in the year that are reasonably expected to be taken in the following year represents amounts that can be estimated with a reasonable amount of accuracy and whose recipients are known and, therefore, is an amount that has been incurred in the year. ...

26 August 1992 Memorandum 921728 (April 1993 Access Letter, p. 139, ¶C56-222)-- summary under Paragraph 60(o) Summary Under Tax Topics- Income Tax Act- Section 60- Paragraph 60(o) Legal and accounting fees respecting a voluntary disclosure are not deductible under s. 60(o). ...

19 November 1992 Memorandum 923036 (September 1993 Access Letter, p. 424, ¶C144-240)-- summary under Subsection 147(2) Summary Under Tax Topics- Income Tax Act- Section 147- Subsection 147(2) Although a pension plan could have two separate trusts relating to two sets of defined benefit provisions, if the plan was adequately funded an employer would not be able to make a contribution on the basis that assets relating to one of the defined benefit provisions were deficient. ...

22 April 1992 Memorandum 920983 (May 1993 Access Letter, p. 191, ¶C20-069)-- summary under Subsection 13(28) Summary Under Tax Topics- Income Tax Act- Section 13- Subsection 13(28) A building purchased by a taxpayer requiring extensive renovations will be eligible for capital cost allowance claims in the year of acquisition. ...

29 July 1993 Internal T.I. 9320007 F- Investment By Way of Contributed Surplus-- summary under Paragraph 20(1)(c) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c) "The deduction of interest should not be denied to a Canadian corporation that borrows funds to invest in a subsidiary, by way of contributed surplus provided the funds are to be used in a business to earn income and it is reasonable to expect that dividends will be earned by the Canadian corporation in the foreseeable future. ...