Search - 德国民法典第1993条

1993 CALU Conference, Q. 2 (C.T.O. "Insurance Policy and Fair Market Value of Shares- CALU")-- summary under Subsection 104(4) Summary Under Tax Topics- Income Tax Act- 101-110- Section 104- Subsection 104(4) Where a spousal trust owns shares of a corporation that owns an insurance policy on the life of the spouse, in determining the fair market value of the shares upon the death of the spouse for purposes of the deemed disposition rule in s. 104(4), the amount the corporation will be entitled to receive under the policy as a consequence of the death of the spouse will be taken into account, given that for purposes of s. 104(4) there is no provision comparable to s. 70(5.3) that will limit the fair market value of the insurance policy. ...

11 February 1993 Memorandum (Tax Window, No. 29, p. 9, ¶2428)-- summary under Paragraph 108(2)(a) Summary Under Tax Topics- Income Tax Act- 101-110- Section 108- Subsection 108(2)- Paragraph 108(2)(a) suspension of redemptions when suspension in trading The requirements of s. 108(2)(a)(i) will be considered to be met even though the administrator of the unit trust may suspend redemption of units when normal trading is suspended in securities held by the fund that represent more than 50% of its total net assets, or during any period not exceeding 120 days during which the fund administrator determines that disposal of this portfolio of securities is not reasonably practicable, or that it is not reasonably practicable to determine fairly the net asset value of the fund. ...

9 March 1993 Memorandum (Tax Window, No. 29, p. 10, ¶2453)-- summary under Subsection 122(1) Summary Under Tax Topics- Income Tax Act- Section 122- Subsection 122(1) Where the residuary beneficiaries of a non-spousal testamentary trust that provides for the distribution to a third beneficiary of all the proceeds of an RRSP of the deceased reimburse the estate for all tax paid as a result of the inclusion in the deceased's terminal return of the RRSP proceeds, and no election is made under s. 104(13.1) or (13.2), the trust will lose its status as a testamentary trust for the taxation year in which the contribution is made. ...

10 February 1993 Memorandum (Tax Window, No. 29, p. 5, ¶2432)-- summary under Non-Business-Income Tax Summary Under Tax Topics- Income Tax Act- Section 126- Subsection 126(7)- Non-Business-Income Tax Foreign tax paid in respect of a capital gains reserve that was included in income in the foreign jurisdiction would normally qualify as a non-business income tax, i.e., provided the taxpayer has s. 126(1)-type income from a particular country, it is not necessary that there be any income from that country for Canadian tax purposes to which the non-business income tax directly relates. ...

Memorandum D11-6-5 Interest and Penalty Provisions: Determinations/Re-determinations, Appraisals/Re-appraisals, and Duty Relief, 4 January 1993-- summary under Subsection 33.4(1) Summary Under Tax Topics- Other Legislation/Constitution- Federal- Customs Act- Section 33.4- Subsection 33.4(1) 12. ...

Revenue Canada Round Table, Q. 30 (May 1993 Access Letter, p. 228)-- summary under Subsection 104(5.5) Summary Under Tax Topics- Income Tax Act- Section 104- Subsection 104(5.5) S.104(5.5)(b) could have application where an individual is given a nominal absolute interest under a trust or a contingent interest which is virtually certain not to vest, no other beneficiary under the trust qualifies as an exempt beneficiary and the only practical reason for having the individual as a beneficiary is to allow the trust to qualify for the election under s. 104(5.3) ...

Annual Conference, Q. 8 (January- February 1993 Access Letter, p. 53)-- summary under Subsection 110.6(8) Summary Under Tax Topics- Income Tax Act- Section 110.6- Subsection 110.6(8) Where a corporation has issued voting participating shares that are not prescribed shares because of the conversion privilege, the average annual rate of return on those shares will be determined based on the assumption that the proceeds to be received by the investor upon disposition of the shares are $100. ...

21 October 1992 Memorandum (Tax Window, No. 27, p. 13, ¶2345; October 1993 Access Letter, p. 476)-- summary under Subsection 5903(3) Summary Under Tax Topics- Income Tax Regulations- Regulation 5903- Subsection 5903(3) Where the amalgamation of two unrelated taxable Canadian corporations precedes the merger of their respective wholly-owned U.S. subsidiaries under a foreign merger as defined in s. 87(8.1), Regulation 5903(3) will specifically include in the deductible loss calculation of the U.S. amalgamated corporation the deductible losses which arose during the periods throughout which the two U.S. predecessors were foreign affiliates of their respective Canadian parents. ...

IT-109R2 "Unpaid Amounts" 23 April 1993-- summary under Subsection 78(1) Summary Under Tax Topics- Income Tax Act- Section 78- Subsection 78(1) 15. ...

1993 APFF Roundtable, Q.1-- summary under Paragraph 256(1)(a) Summary Under Tax Topics- Income Tax Act- Section 256- Subsection 256(1)- Paragraph 256(1)(a) Where a wholly-owned subsidiary ("Holdco II") of Holdco I is the sole general partner of three limited partnerships which, in turn, each hold 1/3 of the shares of Opco, Opco will be considered to be controlled by Holdco II (and therefore associated with Holdco I)- even though the general partner interest of Holdco II is not sufficient to deem a sufficient number of Opco shares to be owned by Holdco II so as to give rise to control by Holdco II- given that Holdco II appears to have de jure control of Opco. ...