Search - 德国民法典第1993条

14 April 1993 T.I. (Tax Window, No. 30, p. 6, ¶2491)-- summary under Paragraph 39(1)(c) Summary Under Tax Topics- Income Tax Act- Section 39- Subsection 39(1)- Paragraph 39(1)(c) Re whether s. 39(1)(c) does not require the corporation to be a small business corporation when a debt is incurred, but only when there is a disposition of the debt. ...

3 February 1992 T.I. 912951 (March 1993 Access Letter, p. 73 ¶C82-111; Tax Window, No. 16, p. 22, ¶1724)-- summary under Subsection 5904(2) Summary Under Tax Topics- Income Tax Regulations- Regulation 5904- Subsection 5904(2) A return of paid-up capital of a foreign affiliate does not constitute a distribution for purposes of Regulation 5904(2)(a). ...

14 August 1992 T.I. 921331 (May 1993 Access Letter, p. 192, ¶C20-070)-- summary under A Summary Under Tax Topics- Income Tax Act- Section 13- Subsection 13(21)- Undepreciated Capital Cost- A Software is acquired by a person where there has been an absolute transfer of all intellectual property interests in the software and where the transferee obtains an unrestricted right to sell or lease the software. ...

A (May 1993 Access Letter, p. 228)-- summary under Subsection 50(1) Summary Under Tax Topics- Income Tax Act- Section 50- Subsection 50(1) The deemed disposition likely does not occur on a debt owing by a corporation all of whose other loans have been called by the bank so long as interest continues to be paid on the debt. ...

26 January 1993 T.I. (Tax Window, No. 28, p. 1, ¶2383)-- summary under Subsection 245(4) Summary Under Tax Topics- Income Tax Act- Section 245- Subsection 245(4) Whether s. 245(2) would apply where a profitable corporation provides services at less than fair market value to an affiliated company with losses would be a question of fact. ...

13 November 1992 T.I. 923187 (September 1993 Access Letter, p. 423, ¶C144-239)-- summary under Disposition Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Disposition Where a subscriber to an RESP names another person's child as a beneficiary in consideration of the receipt of a lump sum, the subscriber will thereby be disposing of a property giving rise to a capital gain. ...

26 February 1993 T.I. (Tax Window, No. 29, p. 19, ¶2448)-- summary under Subparagraph 212(1)(d)(vi) Summary Under Tax Topics- Income Tax Act- Section 212- Subsection 212(1)- Paragraph 212(1)(d)- Subparagraph 212(1)(d)(vi) The printing of cartoon characters on bedspreads, sheets and pillow cases would be considered "production or reproduction" for purposes of s. 212(1)(d)(vi). ...

17 August 1992 T.I. 922097 (April 1993 Access Letter, p. 142, ¶C76-064)-- summary under Section 87 Summary Under Tax Topics- Other Legislation/Constitution- Federal- Indian Act- Section 87 Payments under an RRSP have as their source the head office of the financial institution which issued the RRSP and, therefore, will generally not represent personal property situate on the reserve. ...

30 March 1993 T.I. (Tax Window, No. 29, p. 2 ¶2449)-- summary under Subsection 37(1) Summary Under Tax Topics- Income Tax Act- Section 37- Subsection 37(1) An asset can be eligible for the deduction under s. 37(1)(b), in lieu of claiming capital cost allowance, if an election is made under s. 16.1. ...

16 June 1993 T.I. (Tax Window, No. 32, p. 12, ¶2607)-- summary under Subsection 256(2) Summary Under Tax Topics- Income Tax Act- Section 256- Subsection 256(2) An election by a corporation under s. 256(2) will not affect the status of the other two corporations in question for purposes of ss.129(6) and 181.5(7). ...