Search - 德国民法典第1993条

25 January 1993 Memorandum (Tax Window, No. 28, p. 22, ¶2398)-- summary under Subsection 104(2) Summary Under Tax Topics- Income Tax Act- 101-110- Section 104- Subsection 104(2) Two trusts need not operate concurrently nor need the trustees be the same for a designation under s. 104(2) to be made. ...

Tax Professionals Mini Round Table- Vancouver- Q. 10 (March 1993 Access Letter, p. 103)-- summary under Paragraph 96(1)(a) Summary Under Tax Topics- Income Tax Act- Section 96- Subsection 96(1)- Paragraph 96(1)(a) Where one of the two equal partners of a partnership leases a building to the partnership, the partnership will be entitled to treat the full amount (as opposed to 50%) paid by it to that partner as a partnershp expense; leasehold improvements will be treated in a similar manner. ...

Revenue Canada Round Table, p. 21 (May 1993 Access Letter, p. 227)-- summary under Paragraph 69(1)(c) Summary Under Tax Topics- Income Tax Act- Section 69- Subsection 69(1)- Paragraph 69(1)(c) Where personal property is transferred to a trust with the creation of a lifetime income interest payable only to the transferor and a residual capital interest payable to another person, then provided the remainder interest was acquired by the trust by way of gift, s. 69(1)(c) generally will deem the trust to have acquired the remainder interest at its fair market value. ...

1993 Conference for Advance Life Underwriting, Q. 13 (931011) (C.T.O. ...

10 March 1993 Memorandum (Tax Window, No. 30, p.22, ¶2473)-- summary under Section 87 Summary Under Tax Topics- Other Legislation/Constitution- Federal- Indian Act- Section 87 Training allowances paid to status Indians are exempt if the Indian qualifies for the allowance through employment, the income from which it is exempt, or if the training allowances is paid by a government and the Indian lives on the reserve, or takes training on the reserve. ...

Annual Conference, Q. 1 (January- February 1993 Access Letter, p. 49)-- summary under Subsection 85(2.1) Summary Under Tax Topics- Income Tax Act- Section 85- Subsection 85(2.1) Where an individual exchanges all the common shares of Opco, having an ACB of $100,000, a paid-up capital of $500,000 and a fair market value of $600,000, for treasury shares of another class having a fair market value and stated capital of $600,000, s. 85(2.1) will only reduce the paid-up capital of the treasury shares received on the exchange at a time of computation subsequent to the time of the exchange, and will not eliminate the deemed dividend. ...

Annual Conference, Q. 9 (January- February 1993 Access Letter, p. 53)-- summary under Qualified Small Business Corporation Share Summary Under Tax Topics- Income Tax Act- 101-110- Section 110.6- Subsection 110.6(1)- Qualified Small Business Corporation Share Where Opco pays a dividend in kind with the appropriate amount to two Holdcos, each owing 50% of its shares, who then, by mutual agreement, purchase a portion of the shares of Opco held by the other Holdco for a purchase price equal to the dividend received by them, RC is prepared to regard the shares of Opco as qualifying immediately after that time. ...

17 May 1993 Memorandum (Tax Window, No. 31, p. 2, ¶2508)-- summary under Paragraph 111(5)(a) Summary Under Tax Topics- Income Tax Act- Section 111- Subsection 111(5)- Paragraph 111(5)(a) Where three shareholders (A, B and C) each owning 1/3 of the shares of LossCo transfer their shares of LossCo to ACo, BCo and CCo, then assuming that a group can be identified (for example, A and B) that controlled LossCo prior to the transfer and a group such as ACo and BCo controlled Lossco after the transfer, there will be an acquisition of control of LossCo. ...

27 July 1992 Letter 9205738 (January- February 1993 Access Letter, p. 10, ¶C9-254)-- summary under Timing Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Timing Given that recent case law in pronouncements of the CICA clarify that matching of expenses with related revenues is required, a limited partnership which is created to pay the selling commission of dealers selling mutual fund units will be required to amortize the selling commissions incurred in 1994 and subsequent years over the same period as that used for accounting periods. ...

Annual Conference, Q. 17 (January- February 1993 Access Letter, p. 56)-- summary under Specified Member Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Specified Member Partners whose only involvement in the partnership business is to answer surveys and to meet from time to time with persons in charge of the SR&ED projects being undertaken by the partnership in order to be informed and to have decisions and budgets approved, would not be considered to be specified members. ...