Search - 德国民法典第1993条

28 January 1993 T.I. (Tax Window, No. 28, p. 9, ¶2403)-- summary under Paragraph 153(1)(a) Summary Under Tax Topics- Income Tax Act- Section 153- Subsection 153(1)- Paragraph 153(1)(a) A Canadian-resident loan-out corporation will be required to make deductions at source on any salaries paid to the artist-employee even though the salary pertains to services rendered outside of Canada that may be taxable in the country where the services are rendered. ...

19 May 1993 T.I. (Tax Window, No. 31, p. 5, ¶2512)-- summary under Subsection 146(10) Summary Under Tax Topics- Income Tax Act- Section 146- Subsection 146(10) The transfer, following the writing by an RRSP of a covered call option, of the underlying securities to a broker or a dealer until the option is exercised or expires will not be considered to be the borrowing of money on the security of those investments for the purposes of s. 146(10)(b). ...

19 May 1993 T.I. (Tax Window, No. 31, p. 5, ¶2512)-- summary under Subsection 146(9) Summary Under Tax Topics- Income Tax Act- Section 146- Subsection 146(9) S.146(9) will not be applied to the annuitant where a security of an RRSP is disposed of as a result of a covered call option previously written by the RRSP being exercised. ...

19 May 1993 T.I. (Tax Window, No. 31, p. 5, ¶2512)-- summary under Paragraph 4900(1)(e) Summary Under Tax Topics- Income Tax Regulations- Regulation 4900- Subsection 4900(1)- Paragraph 4900(1)(e) A put option is not a qualified investment as it is a right to dispose of, rather than to acquire, a security. ...

H (May 1993 Access Letter, p. 230)-- summary under Subsection 80.4(2) Summary Under Tax Topics- Income Tax Act- Section 80.4- Subsection 80.4(2) RC is not aware of any situations where the application of s. 80.4 to loans between non-residents should be considered to produce an inappropriate result. ...

18 May 1993 T.I. (Tax Window, No. 31, p. 8, ¶2517)-- summary under Paragraph 149(1)(j) Summary Under Tax Topics- Income Tax Act- Section 149- Subsection 149(1)- Paragraph 149(1)(j) Discussion of criteria for determining whether approval of a research institute or similar organization will be granted. ...

17 August 1992, T.I. 921353 (April 1993 Access Letter, p. 135, ¶C20-1141)-- summary under Effective Date Summary Under Tax Topics- General Concepts- Effective Date Forgiveness of accrued interest has legal effect from the date of the amendment to the debt obligation or such later date as is provided in the amendment. ...

31 March 1993 T.I. (Tax Window, No. 29, p. 23, ¶2451)-- summary under Subsection 104(4) Summary Under Tax Topics- Income Tax Act- 101-110- Section 104- Subsection 104(4) Although s. 104(4) generally applies to revocable trusts, it does not apply to property held by bare trusts. ...

10 February 1993 T.I. (Tax Window, No. 28, p. 20, ¶2419)-- summary under Subsection 118.1(2) Summary Under Tax Topics- Income Tax Act- Section 118.1- Subsection 118.1(2) Where an individual has made an anonymous gift through an agent, she will not be able to comply with the requirements of Regulations 3501 that the receipt shows her name and address, with the result that no credit will be available. ...

20 August 1992 Memorandum 922092 (April 1993 Access Letter, p. 130, ¶C5-190; Tax Window, No. 23, p. 21, ¶2159)-- summary under Paragraph 6(1)(f) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(f) Benefits which arise subsequent to the conversion of a taxable plan to a non-taxable plan are included in income unless those benefits are in no way conditional on participation in the old plan. ...