Search - 德国民法典第1993条

10 December 1993 Income Tax Severed Letter 9333055- Witholding Tax Exemption-- summary under Subparagraph 212(1)(b)(vii) Summary Under Tax Topics- Income Tax Act- Section 212- Subsection 212(1)- Subparagraph 212(1)(b)(vii) "In a situation where interest is computed by reference to dividends paid or payable to shareholders of any class of shares of the capital stock of a corporation, the interest shall be deemed not to be interest for purposes of subparagraph 212(1)(b)(vii) of the Act, by virtue of the postamble thereto, notwithstanding that the dividend component of a particular formula at the time of payment of interest is nil. ...

16 December 1993 Income Tax Severed Letter 9316105- Remainder Interest in Land-- summary under Subsection 73(3) Summary Under Tax Topics- Income Tax Act- Section 73- Subsection 73(3) A remainder interest in land is "land" for purposes of s. 73(3) if the requirements in IT-268R3, para. 9 are satisfied and, if all other conditions under that subsection are met, the provisions of s. 73(3) will apply on its transfer and the provisions of s. 43.1(1) will not. ...

17 December 1993 Income Tax Severed Letter 9323875- Specified Leasing Property Rules-- summary under Subsection 1100(1.11) Summary Under Tax Topics- Income Tax Regulations- Regulation 1100- Subsection 1100(1.11) "The circumstances of a particular fact situation will determine whether a sublease causes the property to become 'specified leasing property'. ...

8 December 1993 Income Tax Severed Letter 9333680- Option Agreements—Non-arm's length Situations-- summary under Paragraph 69(1)(b) Summary Under Tax Topics- Income Tax Act- Section 69- Subsection 69(1)- Paragraph 69(1)(b) Where a company acquires from a person with whom it does not deal at arm's length an option to acquire property at a fixed price, s. 69(1)(b) "could be applied when the option is granted, if not granted at fair market value. ...

8 April 1993 Income Tax Severed Letter 9236345- Spousal Trust and Subsection 104(13.1) Designation-- summary under Subsection 104(13.1) Summary Under Tax Topics- Income Tax Act- 101-110- Section 104- Subsection 104(13.1) Where a spouse is entitled to receive all the income of a testamentary spousal trust but revokes in writing his or her right to receive such income in a given year, a valid designation may be made under s. 104(13.1). ...

2 June 1993 Income Tax Severed Letter 9301835- At-risk Amount—Partnership General-- summary under Paragraph 96(2.2)(d) Summary Under Tax Topics- Income Tax Act- Section 96- Subsection 96(2.2)- Paragraph 96(2.2)(d) The amount of reduction under s. 96(2.2)(d) at any particular time to a limited partner's at-risk amount as a result of limited recourse borrowings obtained by the partner will be the amount of the limited recourse borrowings outstanding at that time. ...

28 June 1993 Income Tax Severed Letter 9307365- Directors Liability Insurance-- summary under Paragraph 6(1)(a) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a) A taxable benefit will not be conferred on a director or officer of a corporation as a result of the corporation paying insurance premiums or her receiving a settlement from the insurance company where the risks covered by the policy are inherent and normal occurrences in carrying out the duties of the insured. ...

21 October 1993 Income Tax Severed Letter 9325325- Mortgage Pay-out Penalties-- 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) loan penalty on sale Where penalty payments are made in order to pay off a mortgage, or reduce the interest rate on a mortgage, prior to the sale of the mortgaged capital property, the payment will be considered to have been made or incurred for the purpose of making the disposition and s. 40(1)(a)(i) will be applicable. ...

27 October 1993 Income Tax Severed Letter 9319925- Farm Support Payments-- summary under Paragraph 12(1)(x) Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(1)- Paragraph 12(1)(x) inclusion re forgivable loan at time of advance A loan from the Agricultural Credit Corporation of Saskatchewan generally would be regarded as a forgivable loan and, therefore, as assistance "to the extent that the lender is committed to forgive the loan if certain conditions are met by the borrower. ...

22 November 1993 Income Tax Severed Letter 9323365- Non-profit Organization—Terminal Losses-- summary under Subsection 149(10) Summary Under Tax Topics- Income Tax Act- Section 149- Subsection 149(10) Where an exempt corporation has depreciable property at the time it ceases to be an exempt corporation, and it realizes a terminal loss pursuant to s. 149(10)(b), it will be able to claim that amount in a future year only to the extent it could not be deducted in the year ending at the time of the change of status or as a non-capital loss in the three preceding years. ...