Search - 德国民法典第1993条

Brian Darling, "Revenue Canada Perspectives" in Income Tax and Goods and Services Tax Considerations in Corporate Financing, 1992 Corporate Management Tax Conference Report (Canadian Tax Foundation, 1993), 5-- summary under Subsection 5907(6) Summary Under Tax Topics- Income Tax Regulations- Regulation 5907- Subsection 5907(6) 1-20, question 7, at 5:13: [w]hat is reasonable in the circumstances can be determined on a case-by-case basis. ...

1 December 1992 Memorandum (Tax Window, No. 27, p. 11, ¶2352; October 1993 Access Letter, p. 475)-- summary under Subparagraph 115(1)(a)(ii) Summary Under Tax Topics- Income Tax Act- Section 115- Subsection 115(1)- Paragraph 115(1)(a)- Subparagraph 115(1)(a)(ii) Where a non-treaty country subsidiary of a Canadian corporation manufactures or process goods outside Canada with no purchasing or processing of raw materials taking place in Canada, and it appoints its Canadian parent as agent to sell its products in Canada as well as outside Canada in consideration for a sales-based commission and with authority granted to its parent to negotiate and conclude sales contracts in its name, RC will ignore the agency relationship with the parent and consider the subsidiary to have Canadian business income equal to all income from Canadian sales of its product minus costs incurred to earn that income. ...

1 December 1993 Annual CTF Roundtable, Q.16, 932866-- summary under Disposition Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Disposition merger of foreign debtor Is there a disposition of a debt of a foreign corporation owned by a Canadian corporation when that foreign corporation is merged with another foreign corporation? ...

P-102 "Seizures and Repossessions" 11 November 1993-- summary under Subsection 183(9) Summary Under Tax Topics- Excise Tax Act- Section 183- Subsection 183(9) voluntary transfer by defaulted mortgagor Example No. 9 A mortgagor cannot meet the mortgage payments and other financial obligations associated with his farmland. ...

IT-363R2 (Cancelled) – Deferred Profit Sharing Plans – Deductibility of Employer Contributions and Taxation of Amounts Received by a Beneficiary 28 May 1993-- summary under Subsection 147(10.1) Summary Under Tax Topics- Income Tax Act- Section 147- Subsection 147(10.1) 14. ...

17 May 1993 Memorandum (Tax Window, No. 31, p. 11, ¶2522)-- summary under Paragraph 111(3)(b) Summary Under Tax Topics- Income Tax Act- Section 111- Subsection 111(3)- Paragraph 111(3)(b) Except as provided in s. 111(3)(b), s. 111 does not impose an ordering on the application of losses and, therefore, a taxpayer can claim losses in the manner which is most beneficial. ...

10 February 1993 Memo 9300776-- summary under Subsection 20(12) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(12) source of income requirement After noting that under the "current" (pre-1992) version of s. 20(12) "a subsection 20(12) deduction does not have to be sourced against a particular type of income (i.e. employment, business or property income)," CRA stated: Consequently, in situations where a non-business-income tax is paid on amounts which are not, or may never be, subject to Canadian tax, income which should properly be taxed in Canada is inappropriately sheltered. ...

P-099 "The Meaning of 'Hotel', 'Motel', 'Inn', 'Boarding House', 'Lodging House' and 'Other Similar Premises', as used in the definition of 'Residential Complex' and 'Residential Unit'" 16 December 1993-- summary under Residential Complex Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Residential Complex The determination of whether an establishment is a hotel, motel, inn, boarding house, lodging house or other similar premise, should be based on...all the following guidelines.... the establishment normally provides temporary accommodation rather than a permanent place of residence; where required by municipal and/or provincial regulations, the establishment is licensed for business for the purpose of providing a temporary place to stay; the establishment is available for rental to the public on a temporary [transient] basis [For this purpose, the public is considered to be either the community as a whole or a defined class of the public, such as students or senior citizens. ...

Memorandum D11-6-5 Interest and Penalty Provisions: Determinations/Re-determinations, Appraisals/Re-appraisals, and Duty Relief, 4 January 1993-- summary under Section 3.2 Summary Under Tax Topics- Other Legislation/Constitution- Federal- Customs Act- Section 3.2 Criteria for the Application of the Prescribed Rate of Interest Levied as a Result of Decisions under Sections 34 and 58 to 94 of the Customs Act or the Provisions of Part II of the Customs Tariff (As specified by the Minister) 1. ...

.- Q.26-- summary under Paragraph (d) Summary Under Tax Topics- Income Tax Act- Section 66.1- Subsection 66.1(6)- Canadian exploration expense- Paragraph (d) Where a well that originally was drilled in 1988 is re-entered in 1993 and drilled to a deeper zone resulting in the discovery of a new pool, well recompletion costs related to the portion of the well that was drilled in 1993, the portion of the well that had been drilled in 1988 and the level where production was taken prior to discovery of the new reserves, would be considered to be CEE. ...