Search - 德国民法典第1993条

The Queen v Silden, 1993 (FCA) 93 DTC 5362 Series of loans or other transactions and repayments As mentioned earlier, subsection 15(2.6) provides that if the loan is repaid within one year from the end of the tax year of the lender in which the loan was made, and if the repayment is not part of a series of loans or other transactions and repayments, the loan is not included in the income of the borrower under subsection 15(2). ... These are important court decisions dealing with bona fide repayments of shareholder loan accounts that are not part of a series of loans and repayments: Attis v MNR, 1992 (TCC) 92 DTC 1128 Uphill Holdings Ltd. et al. v MNR, 1993 (TCC) 93 DTC 148 For more information, go to paragraphs 27, 28, and 29 of Income Tax Interpretation Bulletin IT119R4, Debts of Shareholders and Certain Persons Connected with Shareholders. ... In her capacity as an employee, it is $4,601. 24.12.7 References Income Tax Interpretation Bulletins IT119R4, Debts of Shareholders and Certain Persons Connected with Shareholders IT421R2, Benefits to individuals, corporations, and shareholders from loans or debt Court cases Loan and indebtedness Liffman et al. v MNR, 1990 (TCC) 90 DTC 1854 AC Simmonds & Sons Ltd. v MNR, 1989 (TCC) 89 DTC 707 Subsection 15(2) of the ITA– Canadian Charter of Rights and Freedoms Laflamme v MNR, 1993 (TCC) 93 DTC 50 Whether an estate was connected to the shareholders of a corporation Wright Estate v The Queen, 1996 (TCC) 96 DTC 1509 Demand loans Perlingieri v MNR, 1993 (TCC) 93 DTC 158 Loan received as borrower or shareholder Wolinsky et al. v MNR, 1990 (TCC) 90 DTC 1854 Loan documentation Tick v MNR, 1972 (FCTD) 72 DTC 6135 D'Astous et al. v MNR, 1985 (TCC) 85 DTC 440 Training product TD1019-000, Shareholder’s Debt and Loans Income Tax Rulings Document No. 9606625, May 3, 1996, Société Rattachée aux Associés Actionnaires (available in French only) Document No. 9639060, December 10, 1996, Terms of repayment of shareholder loan exempt by reason of subsection 15(2.3) Document No. 9234987, January 27, 1993, Foreign holiday dwelling Document No. 9509745, August 11, 1995, Shareholder/Employee Housing Loan 15(2), 80.4 Some of the comments in 24.12.4 were taken from TOM 13(15) 2.1 to 2.4. ...

The Queen v Silden, 1993 (FCA) 93 DTC 5362 Series of loans or other transactions and repayments As mentioned earlier, subsection 15(2.6) provides that if the loan is repaid within one year from the end of the tax year of the lender in which the loan was made, and if the repayment is not part of a series of loans or other transactions and repayments, the loan is not included in the income of the borrower under subsection 15(2). ... These are important court decisions dealing with bona fide repayments of shareholder loan accounts that are not part of a series of loans and repayments: Attis v MNR, 1992 (TCC) 92 DTC 1128 Uphill Holdings Ltd. et al. v MNR, 1993 (TCC) 93 DTC 148 For more information, go to paragraphs 27, 28, and 29 of Income Tax Interpretation Bulletin IT119R4, Debts of Shareholders and Certain Persons Connected with Shareholders. ... In Madison’s capacity as an employee, it is $4,601. 24.12.7 References Income Tax Interpretation Bulletins IT119R4, Debts of Shareholders and Certain Persons Connected with Shareholders IT421R2, Benefits to individuals, corporations, and shareholders from loans or debt Court cases Loan and indebtedness Liffman et al. v MNR, 1990 (TCC) 90 DTC 1854 AC Simmonds & Sons Ltd. v MNR, 1989 (TCC) 89 DTC 707 Subsection 15(2) of the ITA– Canadian Charter of Rights and Freedoms Laflamme v MNR, 1993 (TCC) 93 DTC 50 Whether an estate was connected to the shareholders of a corporation Wright Estate v The Queen, 1996 (TCC) 96 DTC 1509 Demand loans Perlingieri v MNR, 1993 (TCC) 93 DTC 158 Loan received as borrower or shareholder Wolinsky et al. v MNR, 1990 (TCC) 90 DTC 1854 Loan documentation Tick v MNR, 1972 (FCTD) 72 DTC 6135 D'Astous et al. v MNR, 1985 (TCC) 85 DTC 440 Training product TD1019-000, Shareholder’s Debt and Loans Income Tax Rulings Document No. 9606625, May 3, 1996, Société Rattachée aux Associés Actionnaires (available in French only) Document No. 9639060, December 10, 1996, Terms of repayment of shareholder loan exempt by reason of subsection 15(2.3) Document No. 9234987, January 27, 1993, Foreign holiday dwelling Document No. 9509745, August 11, 1995, Shareholder/Employee Housing Loan 15(2), 80.4 Some of the comments in 24.12.4 were taken from TOM 13(15) 2.1 to 2.4. ...

The reference to calcium chloride applies to taxation years commencing after 1984 and the reference to diamond deposits is effective only for the 1993 and subsequent taxation years. ...

We have revised this bulletin to incorporate the amendments to the Income Tax Act enacted by: S.C. 1994, c. 7, Schedule II (1991, c. 49-- formerly Bill C-18), S.C. 1994, c. 7, Schedule VIII (1993, c. 24-- formerly Bill C-92), S.C. 1995, c. 3 (formerly Bill C-59), and S.C. 1995, c. 21 (formerly Bill C-70). ...

The comments in the bulletin are not affected by proposed amendments to the Income Tax Act contained in Bill C-9, which received first reading in the House of Commons on February 4, 1994, or in the draft legislation released on August 30, 1993 (a Bill for this legislation will likely be introduced in the House in the current session of Parliament). ...

New ¶ 12 (former ¶ 9) has been revised to reflect the repeal of: the refundable federal sales tax credit, applicable to 1991 and later years; and the refundable child tax credit, applicable to 1993 and later years. ...

The definition reflects changes which took effect for the 1993 and subsequent taxation years. ...

Note: This policy statement supersedes Policy Statement P-080, Medico-Legal Reports dated June 30, 1993. ...

Provision of the Excise Tax Act Circumstance 171(1) and (2) Becoming a registrant 171(4)(a) Ceasing to be a registrant 174 Travel and other allowances 175 Reimbursement of employees and partners 176(1)(a) Acquisition of used goods after 1993 176(1)(b) Acquisition of used goods prior to 1994 177(1) Supply by agent 177(2) Supply for artists, etc. 180(1) Supply by unregistered non resident importer to a registrant in Canada 180(2) Supply by registrant in Canada on behalf of an unregistered non-resident 181(2)(a) Rebate 182 Consequences of a breach, modification or termination of an agreement 183(3)(b) Use of seized property 184(3)(b) Use of property acquired by insurer in the course of settling an insurance claim 184(4)(b) Supply of property acquired by insurer in the course of settlement of an insurance claim 185(1) Financial services incidental to commercial activities of non-financial institutions 185(2) Financial service relating to commercial activity of an individual 186(1) Related corporations 186(2) Takeover fees 186(3) Shares, etc. held by corporation 188(1) Prizes 188(5) ITC of prescribed registrant 191(7) Remote work site 193(1) Taxable sale of real property by registrant 193(2) Sale by public sector bodies 194 Incorrect statement as to use of real property 199(2) Acquisition of capital personal property 199(3) Change of use of capital personal property 199(4) Improvement of capital personal property 199(5) Use of musical instrument 201 ITC for purchase of passenger vehicle 202(2)- (5) Passenger vehicles or aircraft 203(1) Sale of passenger vehicle 206(2) Deemed acquisition of capital real property 206(3) Increase in use of capital real property 208(2) Capital real property used in commercial activities by a registrant individual 208(3) Increase in use of capital real property by registrant individual 209- 210 Public sector bodies and capital real property 211(1) Election respecting real property of public service bodies 211(2) Deemed taxable sale of real property by election 211(4) Deemed sale where election revoked APPENDIX E Legislative provisions permitting deductions in determining net tax. ...

In 1993, the commercial use drops to 35 per cent. The registrant is considered to have sold the computer at its fair market value at that time. ...