Search - 德国民法典第1993条

Tax Executives Institute Round Table, Q. 5 (October 1993 Access Letter, p. 478)-- summary under Subsection 1100(16) Summary Under Tax Topics- Income Tax Regulations- Regulation 1100- Subsection 1100(16) Because a joint venture is not recognized by a statute, each corporate joint venturer must account separately for its gross revenue test under Regulation 1100(16). ...

31 May 1993 Memorandum (Tax Window, No. 32, p. 15, ¶2613)-- summary under Paragraph 2(3)(b) Summary Under Tax Topics- Income Tax Act- Section 2- Subsection 2(3)- Paragraph 2(3)(b) A list of the factors considered in determining whether a taxpayer is carrying on business in Canada. ...

Annual Conference, Q. 14 (January- February 1993 Access Letter, p. 55)-- summary under Subsection 165(3) Summary Under Tax Topics- Income Tax Act- Section 165- Subsection 165(3) It is RCT's policy not to make reassessments which seek to increase the tax payable unless the taxation year is not otherwise statute-barred, there is a valid waiver, or there was a misrepresentation of the facts or fraud. ...

19 June 1992 Interpretation 9218430 (January- February 1993 Access Letter, p. 25, ¶C104-038)-- summary under Subsection 105(1) Summary Under Tax Topics- Income Tax Act- 101-110- Section 105- Subsection 105(1) RC is not prepared to extend the decision in Cooper to benefits arising otherwise than in respect of an interest-free loan emanating from a resident testamentary trust. ...

11 January 1993 Memorandum (Tax Window, No. 28, p. 19, ¶2387)-- summary under Paragraph 149(1)(d) Summary Under Tax Topics- Income Tax Act- Section 149- Subsection 149(1)- Paragraph 149(1)(d) Because an Indian band council is not a municipality, a corporation at least 90% of whose shares are owned by a band council will not qualify for exemption under s. 149(1)(d). ...

1993 A.P.F.F. Round Table Q. 4-- summary under Subsection 84.1(1) Summary Under Tax Topics- Income Tax Act- Section 84.1- Subsection 84.1(1) It is not relevant to the application of s. 84.1 whether the subject corporation and the purchaser corporation were connected before the disposition in question; i.e., there is no requirement that they become connected. ...

1993 A.P.F.F. Round Table Q. 6-- summary under Subsection 86(2) Summary Under Tax Topics- Income Tax Act- Section 86- Subsection 86(2) S.86(2) normally should not apply to an estate refreeze in which preferred shares having a redemption value of $2 million and a fair market value of $1.5 million are exchanged for shares of a new class that are redeemable for $1.5 million. ...

26 January 1993 Memorandum (Tax Window, No. 28, p. 15, ¶2399)-- summary under Subparagraph 40(1)(a)(i) Summary Under Tax Topics- Income Tax Act- Section 40- Subsection 40(1)- Paragraph 40(1)(a)- Subparagraph 40(1)(a)(i) Legal fees incurred by a taxpayer in a year subsequent to the sale of a capital property in order to collect the proceeds of disposition will not be deductible in calculating the gain from the original disposition or on any other basis. ...

Annual Conference, Q. 18 (January- February 1993 Access Letter, p. 57)-- summary under Subsection 45(2) Summary Under Tax Topics- Income Tax Act- Section 45- Subsection 45(2) An election may be made under s. 45(2) in respect of capital property which does not constitute depreciable property to which s. 13(7)(b) otherwise would apply. ...

Annual Conference, Q. 18 (January- February 1993 Access Letter, p. 57)-- summary under Real Estate Summary Under Tax Topics- Income Tax Act- Section 9- Capital Gain vs. ...