Search - 德国民法典第1993条

1993 A.P.F.F. Round Table, Q. 25-- summary under Article 13 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 13 A capital gain arising as a result of a distribution of paid-up capital on common shares held by a non-resident generally would be exempt under Article XIII(4) of the Canada-U.S. ...

Annual Conference, Q. 4 (January- February 1993 Access Letter, p. 51)-- summary under Subsection 50(1) Summary Under Tax Topics- Income Tax Act- Section 50- Subsection 50(1) Given that the dictionary meaning of "insolvent" refers to incapability of paying debts, a corporation that has neither assets nor debt cannot generally be considered to be insolvent. ...

11 June 1993 Memorandum (Tax Window, No. 32, p. 21, ¶2625)-- summary under Paragraph 149(1)(e) Summary Under Tax Topics- Income Tax Act- Section 149- Subsection 149(1)- Paragraph 149(1)(e) RC would permit an agricultural organization that inadvertently made payments to its members to rectify the situation by requiring its members to make a capital contribution, with interest. ...

Tax Executives Institute Round Table, Q.13 (October 1993 Access Letter, p. 481)-- summary under Paragraph 12(1)(x) Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(1)- Paragraph 12(1)(x) It is a question of fact whether a lease cancellation payment received by a tenant would be excluded from the application of s. 12.1(x) by s. 12(1)(x)(viii). ...

A.1-A.3 (May 1993 Access Letter, p. 225)-- summary under Subsection 2(1) Summary Under Tax Topics- Income Tax Act- Section 2- Subsection 2(1) An individual is resident in Canada if that is where the individual, in a settled routine of life, regularly, normally or customarily lives. ...

Annual Conference, Q. 19 (January- February 1993 Access Letter, p. 57)-- summary under Subsection 75(2) Summary Under Tax Topics- Income Tax Act- Section 75- Subsection 75(2) S.75(2) will apply to a taxpayer who establishes a usufruct for another person with respect to property of which the taxpayer is the naked owner. ...

Tax Professionals Mini Round Table- Vancouver- Q. 4 (March 1993 Access Letter, p. 102)-- summary under Paragraph 7(1)(a) Summary Under Tax Topics- Income Tax Act- Section 7- Subsection 7(1)- Paragraph 7(1)(a) Discussion of criteria for determining the "value" of publicly treated shares for purposes of s. 7(1)(a). ...

Tax Professionals Mini Round Table- Vancouver- Q. 20 (March 1993 Acess Letter, p. 107)-- summary under Subsection 37(1) Summary Under Tax Topics- Income Tax Act- Section 37- Subsection 37(1) If an expenditure on scientific research is on current account and for an income-producing purpose, it is deductible without reference to s. 37. ...

8 February 1993 Memorandum (Tax Window, No. 29, p. 13, ¶2424)-- summary under Section 87 Summary Under Tax Topics- Other Legislation/Constitution- Federal- Indian Act- Section 87 Where an employer has its head office on a reserve, salary and wages paid to employees who also live on the reserve will be tax exempt, and salaries and wages paid to employees who live off the reserve will be taxable. ...

1 December 1992 Memorandum (Tax Window, No. 27, p. 11, ¶2352; October 1993 Access Letter, p. 475)-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 A list of nine criteria for determining whether a Canadian corporation is an independent agent of a U.S. corporation for purposes of Article V(7) of the Canada-U.S. ...