Search - 德国民法典第1993条

13 January 1993 T.I. 922191 (November 1993 Access Letter, p. 500, ¶C76-077)-- summary under Subsection 15(1) Summary Under Tax Topics- Income Tax Act- Section 15- Subsection 15(1) Where a loan is received by an employee of a corporation who owns all its shares, RC will consider that the loan was not contracted qua employee, except under exceptional circumstances. ...

13 January 1993 T.I. 922191 (November 1993 Access Letter, p. 500, ¶C76-077)-- summary under Financing Expenditures Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(b)- Capital Expenditure v. ...

20 January 1993 T.I. 921629 (November 1993 Access Letter, p. 506, ¶C117-209)-- summary under Subsection 126(1) Summary Under Tax Topics- Income Tax Act- Section 126- Subsection 126(1) U.S. taxes payable by a Canadian-resident individual on the sale to a U.S. resident of the shares of a taxable Canadian corporation holding U.S. real estate in respect of which an election previously had been made under s. 897(i) of the IRC would be creditable under s. 126(1). ...

14 January 1993 T.I. 922579 (November 1993 Access Letter, p. 500, ¶C76-076)-- summary under Section 79 Summary Under Tax Topics- Income Tax Act- Section 79 Where a corporation has retained title to land inventory until the purchaser pays the balance of the purchase price, and the purchaser then gives up its rights under the agreement so that the vendor can dispose of the land at fair market value to third parties but requests that the vendor share the proceeds from the land with it, s. 79 will not apply. ...

5 January 1993 T.I. 922053 (November 1993 Access Letter, p. 509, ¶C180-153; Tax Window, No. 28, p. 8, ¶2404)-- summary under Article 12 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 12 Where a Canadian firm agrees with an American firm to duplicate video cassettes for sale or distribution through rental establishments for non-commercial use by the end users, the payments made for such duplication rights will not be subject to Part XIII tax, even though the source of the work might be a motion picture film. ...

26 January 1993 TI 923284 (November 1993 Access Letter, p. 512, ¶245-051; Tax Window, No. 28, p. 1, ¶2383), 923284)-- summary under Income-Producing Purpose Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Income-Producing Purpose Where a profitable corporation provides services at less than fair market value to an affiliated company with losses, s. 18(1)(a) could restrict its deduction for expenses relating to the provision of such services. ...

13 January 1993 T.I. 923260 (November 1993 Access Letter, p. 504, ¶C109-156)-- summary under Qualified Small Business Corporation Share Summary Under Tax Topics- Income Tax Act- 101-110- Section 110.6- Subsection 110.6(1)- Qualified Small Business Corporation Share Where a corporation owned by an individual ("Holdco") sold its shares of Opco to Newco, a newly-incorporated corporation owned by the same individual, and the individual then sold his Holdco shares, the Newco shares of the individual would not be considered to be shares substituted for the Holdco shares. ...

11 January 1993 T.I. 923216 (November 1993 Access Letter, p. 499, ¶C76-075)-- summary under Section 79 Summary Under Tax Topics- Income Tax Act- Section 79 Where an acceleration clause in a debt obligation of a purchaser causes the obligation to become due in the same year as sale, no reserve will be allowed under s. 40(1)(a)(iii) to the creditor in the year of sale. ...

5 January 1993 T.I. 923226 (November 1993 Access Letter, p. 491, ¶C9-290; (Tax Window, No. 28, p. 16, ¶2375)-- summary under Subsection 15(2) Summary Under Tax Topics- Income Tax Act- Section 15- Subsection 15(2) A loan may still qualify after its transfer at fair market value to a related corporation by which the employee is also employed, because the transfer, by itself, will not result in a new loan agreement. ...

8 January 1993 T.I. 923191 (November 1993 Access Letter, p. 488, ¶C5-223)-- 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 awarded the permanent possession of an item of jewellery, he will be regarded as being the beneficial owner thereof. ...