Search - 德国民法典第1993条

1993 A.P.F.F. Round Table, Q. 22-- summary under Small Business Corporation Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Small Business Corporation Assets which "are not directly used in the active business carried on by the corporation because of unfavourable market conditions could nevertheless be considered to be 'used principally' for the purpose of the definition of small business corporation, if it is clear that the discontinuance is only temporary and the company intends to use these assets in its business soon". ...

B.9 (May 1993 Access Letter, p. 226)-- summary under old Summary Under Tax Topics- Income Tax Act- Section 94- old Where the trustee of a unit trust has the discretion as to when the amounts of income or capital are to be distributed to any particular beneficiary, but no discretion as to the amount of income or capital to be distributed, s. 94(1)(d) rather than (c) will apply. ...

Tax Professionals Mini Round Table- Vancouver- Q. 16 (March 1993 Access Letter, p. 105)-- summary under Subsection 2(1) Summary Under Tax Topics- Income Tax Act- Section 2- Subsection 2(1) RC recognizes that an individual who is resident both in Canada and the U.S. under the Income Tax Act and the Internal Revenue Code but who is a resident of the U.S. for treaty purposes will therefore not be considered to be resident in Canada. ...

Annual Conference, Q. 20 (January- February 1993 Access Letter, p. 58)-- summary under Subsection 146(8.8) Summary Under Tax Topics- Income Tax Act- Section 146- Subsection 146(8.8) In light of the definition of "spouse" in s. 146(1.1), a deduction may be obtained under s. 146(8.8) for the transfer of a portion of an RRSP fund to a legal spouse (i.e., the surviving wife from whom the taxpayer was separated but not yet divorced) and to the transfer of the balance of the fund to a common law spouse. ...

24 January 1992 Memorandum (Tax Window, No. 16, p. 3, ¶1715, January- February 1993 Access Letter, p. 33, ¶C144- 196)-- summary under Paragraph 149.1(3)(a) Summary Under Tax Topics- Income Tax Act- Section 149.1- Subsection 149.1(3)- Paragraph 149.1(3)(a) Guarantee fees received by a charitable foundation for guaranteeing a bank loan to a corporation engaged in scientific research would constitute income from a related business if the foundation used the fee income to carry out its stated objectives. ...

24 January 1992 Memorandum (Tax Window, No. 16, p. 3, ¶1715, January- February 1993 Access Letter, p. 33, ¶C144- 196)-- summary under Paragraph 149.1(3)(d) Summary Under Tax Topics- Income Tax Act- Section 149.1- Subsection 149.1(3)- Paragraph 149.1(3)(d) Where a charitable foundation guarantees a bank loan made to a corporation engaged in scientific research, it will not be considered to have incurred a debt until such time as the corporation defaults on the loan. ...

10 June 1993 Memorandum (Tax Window, No. 32, p. 4, ¶2594)-- summary under Retiring Allowance Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Retiring Allowance Where in an out-of-court settlement of a suit brought in connection with the termination of employment, an amount is allocated as damages for violation of human rights, it must be established that human rights issues were involved and that the payment was reasonable compared to awards ordered by actual tribunals, in order for such amount not to be considered a retiring allowance. ...

Tax Executives Institute Round Table, Q.12 (October 1993 Access Letter, p. 481)-- summary under Subsection 165(1) Summary Under Tax Topics- Income Tax Act- Section 165- Subsection 165(1) Where RC has issued a reassessment under s. 152(4) following an objection by the taxpayer under s. 165(1) to a previous reassessment, the taxpayer may file a notice of objection to the second reassessment, and is not obligated to appeal under s. 165(7). ...

Tax Executives Institute Round Table, Q. 7 (October 1993 Access Letter, p. 479)-- summary under Income-Producing Purpose Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Income-Producing Purpose An indemnity payment made by one corporation to another as a result of additional Part I.3 taxes or provincial capital taxes payable by the other corporation on a transaction will not be deductible to the payor corporation either in full or as an eligible capital expenditure. ...

Tax Executives Institute Round Table, Q. 7 (October 1993 Access Letter, p. 479)-- summary under Subsection 181.2(3) Summary Under Tax Topics- Income Tax Act- Section 181.2- Subsection 181.2(3) Deferred revenue constitutes a "loan or advance" to the corporation. ...