Search - 德国民法典第1993条

Annual Conference, Q. 6 (January- February 1993 Access Letter, p. 52)-- summary under Subsection 6205(2) Summary Under Tax Topics- Income Tax Regulations- Regulation 6205- Subsection 6205(2) Adverse comments on a scheme to retroactively make non-prescribed shares qualify as prescribed shares. ...

13 January 1993 T.I, (Tax Window, No. 28, p. 17, ¶2384)-- summary under Subsection 144(3) Summary Under Tax Topics- Income Tax Act- Section 144- Subsection 144(3) The employee's entitlements under a profit sharing plan are taxable at the time they are allocated to the employee by the trustee. ...

4 June 1993 Memorandum (Tax Window, No. 32, p. 9, ¶2602)-- summary under Retiring Allowance Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Retiring Allowance Where an employee is dismissed, receives an arbitration award and is reinstated in his former position, then if the reinstatement is on a retroactive basis the amounts received in settlement of foregone salary will be included in his employment income even if he did not return to his former employer. ...

4 June 1993 Memorandum (Tax Window, No. 32, p. 9, ¶2602)-- summary under Paragraph 6(1)(a) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a) Where an employee is dismissed, receives an arbitration award and is reinstated to his former position, any amounts received as part of the settlement which are in respect of out-of-pocket expenses incurred by the individual will be considered to be a taxable benefit. ...

Tax Professionals Mini Round Table- Vancouver- Q. 34 (March 1993 Access Letter, p. 113)-- summary under Small Business Corporation Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Small Business Corporation Notwithstanding the decision in Bills Investments Ltd. v. ...

Annual Conference, Q. 1 (January- February 1993 Access Letter, p. 49)-- summary under Subsection 84(1) Summary Under Tax Topics- Income Tax Act- Section 84- Subsection 84(1) Where an individual exchanges all the outstanding common shares of Opco, having a paid-up capital of $500,000 and a fair market value of $600,000, for treasury shares of another class having a stated capital and fair market value of $600,000, he will be deemed under s. 84(1) to receive a dividend of $100,000. ...

1993 A.P.F.F. Round Table, Q.15-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt There is no repayment for the purposes of s. 20(1)(hh) when shares are converted to a debt security and the parties are in essentially the same situation before and after the conversion. ...

1993 A.P.F.F. Round Table, Q.15-- summary under Paragraph 20(1)(hh) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(hh) There is no repayment for the purposes of s. 20(1)(hh) when shares are converted to a debt security and the parties are in essentially the same situation before and after the conversion. ...

7 April 1993 Memorandum (Tax Window, No. 31, p. 6, ¶2513)-- summary under Subsection 112(4) Summary Under Tax Topics- Income Tax Act- Section 112- Subsection 112(4) A standard distress preferred share ruling is that s. 112(4) will not apply in respect of any dividends received by the specified financial institution on the distress preferred shares, to any loss realized by the institution on the debt subsequent to it being reacquired by the institution or to any loss realized by the institution on any loan made by the institution as described. ...

7 April 1993 Memorandum (Tax Window, No. 31, p. 6, ¶2513)-- summary under Subparagraph 20(1)(p)(ii) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(p)- Subparagraph 20(1)(p)(ii) A standard distress preferred share ruling is that provided the debt arose from one or more loans made by the specified financial institution in the course of its money-lending business, the debt reacquired by the institution will be considered to have been acquired by it in the ordinary course of its business of lending money for the purposes of ss.20(1)(l) and (p). ...