Search - 德国民法典第1993条

18 November 1992 Memorandum 921979 (December 1993 Access Letter, p. 407, ¶C9-286)-- summary under Incurring of Expense Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Incurring of Expense A reserve for vacation pay benefits earned by employees in the year that are reasonably expected to be taken in the following year represents amounts that can be estimated with a reasonable amount of accuracy and whose recipients are known and, therefore, is an amount that has been incurred in the year. ...

31 March 1993 T.I. (Tax Window, No. 30, p. 5, ¶2462)-- summary under Subsection 6205(2) Summary Under Tax Topics- Income Tax Regulations- Regulation 6205- Subsection 6205(2) The test in Regulation 6205(2)(a)(ii)(A) would not be met where two individuals each owning ½ of the common shares of a corporation exchange their common shares of the corporation for preferred shares and have the corporation issue common shares to individuals related to one or other of the two shareholders, because "all" of the common shares would not be owned by non-arm's length persons. ...

C (May 1993 Access Letter, p. 229)-- summary under Subsection 152(4.2) Summary Under Tax Topics- Income Tax Act- Section 152- Subsection 152(4.2) S.152(4.2) provides for the establishment of a non-capital loss in a year beyond the normal reassessment period, for example, where a taxpayer has inadvertently capitalized an item which should have been expensed, and the result of claiming the expense would be to produce a non-capital loss. ...

8 February 1993 T.I. (Tax Window, No. 28, p. 2, ¶2416)-- summary under Subsection 85(4) Summary Under Tax Topics- Income Tax Act- Section 85- Subsection 85(4) The capital loss otherwise deemed to be received by the sole individual shareholder of a holding company on the redemption of preferred shares of the holding company having a low paid-up capital and a high redemption amount would be denied by s. 85(4) because he would control the holding company immediately thereafter. ...

23 November 1992 T.I. 920625 (September 1993 Access Letter, p. 421, ¶C117-205)-- summary under Non-Resident-Owned Investment Corporation Summary Under Tax Topics- Income Tax Act- Section 133- Subsection 133(8)- Non-Resident-Owned Investment Corporation In determining whether the principal business of a supposed NRO was trading in securities, it was necessary to determine whether the activities and types of assets in question resulted in the corporation being considered to earn business income rather than income from property. ...

21 December 1993 T.I. HAA7255-7 (C.T.O. "Interest in a Bond as Qualified Investment for RRSP")-- summary under Paragraph 4900(1)(i) Summary Under Tax Topics- Income Tax Regulations- Regulation 4900- Subsection 4900(1)- Paragraph 4900(1)(i) "An 'interest' in a bond or similar obligation that is a qualified investment for an RRSP pursuant to paragraph 4900(1)(i) of the Income Tax Regulations may also be such a qualified investment if the holder of the interest would have the same rights as a direct holder of the bond but for the interposition of an agent or bare trustee". ...

12 August 1992 T.I. 921604 (April 1993 Access Letter, p. 155, ¶C248-134; Tax Window, No. 23, p. 12, ¶2130)-- summary under Subsection 256(5.1) Summary Under Tax Topics- Income Tax Act- Section 256- Subsection 256(5.1) Where a shareholder's agreement between two 50% shareholders provides that each shareholder will elect two members of the board of the directors and that one director elected by the first shareholder will be the chairman of the board and will have a casting vote, that first shareholder will have the de facto control described in s. 256(5.1). ...

22 July 1992, T.I. 921908 (May 1993 Access Letter, p. 189, ¶C9-262)-- summary under Paragraph 12(1)(a) Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(1)- Paragraph 12(1)(a) Up-front payments received by a marketer of timeshare units in order to provide "floating week leasing options" are amounts to which it is absolutely and unconditionally entitled, with the result that they are included in income under s. 9(1) and not under s. 12(1)(a). ...

11 February 1993 T.I. (Tax Window, No. 29, p. 18, ¶2423)-- 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 The two-year gross revenue test in the definition may be applied to any one of the persons described in ss. ...

26 November 1992 T.I. 923506 (September 1993 Access Letter, p. 411, ¶C20-1161)-- summary under Subsection 28(1) Summary Under Tax Topics- Income Tax Act- Section 28- Subsection 28(1) A post-dated cheque received under the Gross Revenue Insurance Program, that is accepted as security for the debt owing to the taxpayer without extinguishing the debt, is brought into income on the date that the cheque is payable. ...