Search - 德国民法典第1993条

23 June 1992 T.I. 921868 (January- February 1993 Access Letter, p. 20, ¶C56-211)-- summary under Joint Exploration Corporation Summary Under Tax Topics- Income Tax Act- Section 66- Subsection 66(15)- Joint Exploration Corporation A principal business corporation that has, throughout its existence, always been a wholly-owned subsidiary of another corporation will qualify as a JEC irrespective of the number of corporations of which it has been such a subsidiary. ...

13 January 1993 T.I. (Tax Window-- summary under Shares Summary Under Tax Topics- General Concepts- Fair Market Value- Shares underline;">, No. 28, p. 22, ¶2370): Preferred shares that carry a dividend based on the prime lending rate, and preferred shares that are entitled to a reasonable discretionary dividend, will be considered to have a fair market value equal to the redemption amount in the context of an estate freeze. ...

30 July 1992 T.I. 921204 (January- February 1993 Access Letter, p. 26, ¶C109-125)-- summary under Qualified Farm or Fishing Property Summary Under Tax Topics- Income Tax Act- 101-110- Section 110.6- Subsection 110.6(1)- Qualified Farm or Fishing Property Comprehensive discussion of the meaning of the phrase "qualified farm property". ...

23 June 1993 T.I. (Tax Window, No. 32, p. 14, ¶2609)-- summary under Qualified Farm or Fishing Property Summary Under Tax Topics- Income Tax Act- 101-110- Section 110.6- Subsection 110.6(1)- Qualified Farm or Fishing Property Real property rented by an individual to a corporation would be considered to be used by the corporation for the purposes of the definition of qualified farm property. ...

G (May 1993 Access Letter, p. 230)-- summary under Subsection 15(1) Summary Under Tax Topics- Income Tax Act- Section 15- Subsection 15(1) The unreasonable portion of salaries or bonuses paid to non-resident shareholder-managers will be subject to Part XIII tax under ss.15(1), 214(3)(a) and 212(2). ...

G (May 1993 Access Letter, p. 230)-- summary under Subsection 212(2) Summary Under Tax Topics- Income Tax Act- Section 212- Subsection 212(2) The unreasonable portion of salaries or bonuses paid to non-resident shareholder-managers will be subject to Part XIII tax under ss.15(1), 214(3)(a) and 212(2). ...

D (May 1993 Access Letter, p. 229)-- summary under Subsection 10(1) Summary Under Tax Topics- Income Tax Act- Section 10- Subsection 10(1) Joint venturers who are engaged in an adventure in the nature of trade are not entitled to write down the value of their land inventory. ...

14 February 1992 T.I. 193385 (January- February 1993 Access Letter, p. 7, ¶C5-182)-- summary under Paragraph 6(1)(f) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(f) Discussion of various issues arising where an employer provides both taxable and non-taxable disability benefits to employees. ...

23 November 1992, T.I. 923079 (September 1993 Access Letter, p. 407, ¶C9-285)-- summary under Qualifying Debt Obligation Summary Under Tax Topics- Income Tax Act- Section 15.1- Subsection 15.1(3)- Qualifying Debt Obligation A transaction that took the form of a lease generally would not establish a debtor/creditor relationship and, therefore, generally would not give rise to a debt for purposes of the financial difficulty provision of paragraph (f). ...

J (May 1993 Access Letter, p. 231)-- summary under Subsection 20(12) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(12) Because the deduction is only available in the computation of income from a business or property, foreign tax paid on the disposition of a foreign principal residence will not give rise to a deduction under s. 20(12). ...