Search - 德国民法典第1993条

24 July 1992 T.I. 921652 (March 1993 Access Letter, p. 75, ¶C104-041)-- summary under Subsection 107(2) Summary Under Tax Topics- Income Tax Act- 101-110- Section 107- Subsection 107(2) It is a question of law whether, upon the variation of a trust, the distribution of property can be said to be made under the terms of a testator's will or another trust, for the purposes of the meeting of "testamentary trust", "personal trust" and s. 248(8)(a). ...

11 March 1993 T.I. (Tax Window, No. 30, p. 22,)2495)-- summary under Subsection 118.6(1) Summary Under Tax Topics- Income Tax Act- Section 118.6- Subsection 118.6(1) Students taking courses provided by the Certified General Accountants Association who are employed in the accounting field will not be entitled to the deduction because of the exception in paragraph (b) of the definition of "qualifying educational program" in s. 118.6(1). ...

24 March 1992 T.I. (920203 (March 1993 Access Letter, p. 76, ¶C109-126; Tax Window, No. 18, p. 24, ¶1827)-- summary under Property Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Property A particular covenant that is a restriction against land and which runs with the land and is binding on the landlord and his successors in title, will qualify as property for purposes of s. 248(1). ...

14 December 1993 Memorandum 931814 (C.T.O. "Bad Debt Reduction for Part of a Loan")-- summary under Subparagraph 20(1)(p)(i) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(p)- Subparagraph 20(1)(p)(i) Review of jurisprudence respecting whether a deduction may be taken under s. 20(1)(p) in respect of a partial debt write-down. ...

E (May 1993 Access Letter, p. 229)-- summary under Non-Resident-Owned Investment Corporation Summary Under Tax Topics- Income Tax Act- Section 133- Subsection 133(8)- Non-Resident-Owned Investment Corporation Funded indebtedness refers to debt obligations that relate to the capital structure of the company, and include bonds, debentures and long-term notes. ...

21 April 1993 T.I. (Tax Window, No. 31, p. 9, ¶2518)-- summary under Subsection 13(27) Summary Under Tax Topics- Income Tax Act- Section 13- Subsection 13(27) A fishing vessel cannot be considered to be capable of performing the function for which it was acquired until all permits, certificates and licences are acquired. ...

18 June 1992 T.I. 921747 (January- February 1993 Access Letter, p. 21, ¶C76-062)-- summary under Section 87 Summary Under Tax Topics- Other Legislation/Constitution- Federal- Indian Act- Section 87 A payment out of an RRSP would not be considered personal property situate on a reserve unless the head office of the financial institution was situate there. ...

26 February 1993 T.I. (Tax Window, No. 29, p.17, ¶2440)-- summary under Paragraph 12(1)(x) Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(1)- Paragraph 12(1)(x) A reimbursement or other assistance received in respect of eligible capital property cannot be applied to offset the cost amount of that property and, instead, must be included in income. ...

2 October 1992 Memorandum 921938 (September 1993 Access Letter, p. 421, ¶C117-204)-- summary under Investment Tax Credit Summary Under Tax Topics- Income Tax Act- Section 127- Subsection 127(9)- Investment Tax Credit An amount erroneously deducted as an ITC in a statute-barred year would be regarded as deducted for purposes of the definition, in light of the decision in Dominion of Canada General Insurance Co. v. ...

P (May 1993 Access Letter, p. 233)-- summary under Paragraph 20(1)(c) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c) Re: deductibility under s. 20(1)(c)(iv) of interest under a reverse mortgage arrangement. ...