Search - 德国民法典第1993条

23 December 1993 Internal T.I. 9335957 F- Overseas Employment Tax Credit-Subcontractor (7070-7)-- summary under Subsection 122.3(1) Summary Under Tax Topics- Income Tax Act- Section 122.3- Subsection 122.3(1) Employees of a sub-contractor may qualify for the credit notwithstanding that the sub-contractor itself is not carrying on a qualified activity provided that the employees' duties are performed outside Canada in connection with a contract under which the sub-contractor carries on business outside Canada with respect to a qualified activity (i.e., of the main contractor). ...

28 July 1992 Memorandum 921859 (April 1993 Access Letter, p. 151, ¶C180-136)-- summary under Subsection 2900(2) Summary Under Tax Topics- Income Tax Regulations- Regulation 2900- Subsection 2900(2) Use of the term "paid" in s. 2900(2)(b) was intended to deny deductions for accruals of salaries, wages and bonuses. ...

23 June 1992 Memorandum 921769 (January- February 1993 Access Letter, p. 28, ¶C117-180)-- summary under Subsection 129(1.2) Summary Under Tax Topics- Income Tax Act- Section 129- Subsection 129(1.2) It would be difficult to conclude that there has been an avoidance of Part IV tax by a recipient corporation where a related group carries out transactions so that a corporation with a balance in its refundable dividend tax on hand account generates a dividend refund on the payment of a dividend, and the recipient corporation eliminates its Part IV tax liability through the deduction of non-capital losses. ...

17 February 1993 Memorandum 93020-- summary under Investment Contract Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(11)- Investment Contract The taxpayer advanced a sum to purchase a shopping mall and subsequently sued to recover the amount. ...

2 December 1993 Memorandum 933330 (C.T.O. "Non-Resident Exercise Stock Option (4093-U5-100-15)")-- summary under Article 15 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 15 A detailed example showing how a stock option benefit ultimately realized by a U.S. ...

1993 Internal T.I. 9325537 F- Election Under Sub-- summary under Disposition Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Disposition "A disposition takes place when a share is cancelled during the process of a voluntary dissolution of a corporation pursuant to clause 54(c)(ii)(A) of the Act. ...

28 April 1993 Internal T.I. 9301657 F- Franchise Royalty Income- Active Business-- summary under Income of the Corporation for the Year From an Active Business Summary Under Tax Topics- Income Tax Act- Section 125- Subsection 125(7)- Income of the Corporation for the Year From an Active Business Discussion of whether lump sum payments received by a franchisor from its franchisees are income from an active business. ...

8 April 1993 Internal T.I. 9238487 F- Trust Money in Dispute-- summary under Paragraph 12(1)(c) Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(1)- Paragraph 12(1)(c) interest income in litigation trust is taxable to trust if no waivers issued Where the litigants and the trustee of a litigation trust have not submitted waivers for each year, income earned by the trust on the trust funds will not be payable to the beneficiaries because the entitlement of the litigants to the funds would not yet be determined. ...

19 August 1991 Memorandum 911368(E)-- summary under Subsection 248(18) Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(18) Where the taxpayer was assessed in July 1993 to deny an input tax credit, appealed successfully to the Tax Court but with the Minister then successfully appealing the Tax Court decision, the "particular time" referred to in s. 248(18) would be July 1993. If the taxpayer had ultimately prevailed in its GST appeal at a time when the July 1993 had become statute-barred, there would be a loss to the fisc. ...

10 May 2001 Internal T.I. 2001-0065827 F- FINES + PENALTIES- INTÉRETS ET PÉNALITÉS-- summary under Paragraph 18(1)(t) Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(t) s. 18(1)(t) enacted for greater certainty CRA noted that Ioegen (96 DTC 1993) found that s. 18(1)(t) was enacted for greater certainty. ...