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Miscellaneous summary
30 November 1993 Income Tax Severed Letter 9332145 - DPSP Qualified Investments -- summary under Equity Share
30 November 1993 Income Tax Severed Letter 9332145- DPSP Qualified Investments-- summary under Equity Share Summary Under Tax Topics- Income Tax Act- Section 204- Equity Share General discussion. ...
Miscellaneous summary
1 December 1993 Income Tax Severed Letter 9332845 - RRSP Non-Resident Contribution Carry Forward -- summary under Subsection 146(5)
1 December 1993 Income Tax Severed Letter 9332845- RRSP Non-Resident Contribution Carry Forward-- summary under Subsection 146(5) Summary Under Tax Topics- Income Tax Act- Section 146- Subsection 146(5) Discussion of rules governing contributions to an RRSP by a non-resident of Canada. ...
Miscellaneous summary
2 June 1993 Income Tax Severed Letter 9301835 - At-risk Amount—Partnership General -- summary under Paragraph 96(2.4)(b)
2 June 1993 Income Tax Severed Letter 9301835- At-risk Amount—Partnership General-- summary under Paragraph 96(2.4)(b) Summary Under Tax Topics- Income Tax Act- Section 96- Subsection 96(2.4)- Paragraph 96(2.4)(b) A partner of a general partnership can be a limited partner for purposes of the at-risk amount rules where the partnership is party to a limited recourse loan which is related to its partners' acquisition of partnership interests. ...
Miscellaneous summary
20 September 1993 Income Tax Severed Letter 9321275 - Life Annuities -- summary under Subsection 70(5.3)
20 September 1993 Income Tax Severed Letter 9321275- Life Annuities-- summary under Subsection 70(5.3) Summary Under Tax Topics- Income Tax Act- Section 70- Subsection 70(5.3) Although a life annuity is a life insurance policy which is issued or effected upon the life of a person, it is not a policy under which the life of the person is insured. ...
Miscellaneous summary
25 October 1993 Income Tax Severed Letter 9324605 - Foreclosure Action Instituted by Mortgagee -- summary under Subsection 116(5.3)
25 October 1993 Income Tax Severed Letter 9324605- Foreclosure Action Instituted by Mortgagee-- summary under Subsection 116(5.3) Summary Under Tax Topics- Income Tax Act- Section 116- Subsection 116(5.3) RC's views concerning a mortgagee instituting a foreclosure action apply in all jurisdictions in Canada, whether the mortgage is registered under the "Torrens" system, or under a "registry" system. ...
Miscellaneous summary
8 December 1993 Income Tax Severed Letter 932271A F - Deduction of RRSP Overcontribution -- summary under Subsection 146(5)
8 December 1993 Income Tax Severed Letter 932271A F- Deduction of RRSP Overcontribution-- summary under Subsection 146(5) Summary Under Tax Topics- Income Tax Act- Section 146- Subsection 146(5) Following the maturation of an RRSP when an annuitant turns 71, she may continue to deduct amounts that were over-contributed to her RRSP so long as she has "earned income" in the previous year. ...
Miscellaneous summary
17 November 1993 Income Tax Severed Letter 9330166 - Membership Fees -- summary under Paragraph 18(1)(l)
17 November 1993 Income Tax Severed Letter 9330166- Membership Fees-- summary under Paragraph 18(1)(l) Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(l) Discussion of the meaning of the phrase "membership fees... in any club the main purpose of which is to provide dining, recreational or sporting facilities for its members". ...
Miscellaneous summary
6 December 1993 Income Tax Severed Letter 9328045 - Registered Investment—Mutual Fund Trust -- summary under Subsection 204.4(4)
6 December 1993 Income Tax Severed Letter 9328045- Registered Investment—Mutual Fund Trust-- summary under Subsection 204.4(4) Summary Under Tax Topics- Income Tax Act- Section 204.4- Subsection 204.4(4) Continued registered investment status under s. 204.4(4) applies to all terminated registered investments including a mutual fund trust whose units are described in Regulation 4900(1)(d). ...
Miscellaneous summary
13 December 1993 Income Tax Severed Letter 9326335 - Transfer Allowance -- summary under Paragraph 6(1)(b)
13 December 1993 Income Tax Severed Letter 9326335- Transfer Allowance-- summary under Paragraph 6(1)(b) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(b) A relocation allowance equal to 1/12 or 1/24 of one year's salary of a member of the RCMP will be taxable as remuneration from employment in light of McLay v. ...
Miscellaneous summary
7 December 1993 Income Tax Severed Letter 9332865 - Large Corporation Tax -- summary under Subsection 181.2(3)
7 December 1993 Income Tax Severed Letter 9332865- Large Corporation Tax-- summary under Subsection 181.2(3) Summary Under Tax Topics- Income Tax Act- Section 181.2- Subsection 181.2(3) Where a corporation that issues bankers' acceptances and deposits the proceeds with the bank in order for the bank to provide operating loans to affiliates of the corporation, the indebtedness represented by the bankers' acceptances will not be reduced by the amount on deposit with the bank. ...