Search - 德国民法典第1993条

30 July 1992 T.I. 921653 (March 1993 Access Letter, p. 72, ¶C82-110)-- summary under Subsection 88(1.1) Summary Under Tax Topics- Income Tax Act- Section 88- Subsection 88(1.1) The application of s. 80 to the parent in its second taxation year ending after the commencement of the winding-up will reduce the non-capital losses of the subsidiary for the previous year that are deemed to be non-capital losses of the parent pursuant to s. 88(1.1) and that otherwise would be available for carry-forward at the end of the first taxation year of the parent ending after the commencement of the winding-up. ...

18 June 1993 T.I. (Tax Window, No. 32, p. 15, ¶2611)-- summary under Subsection 122.3(1) Summary Under Tax Topics- Income Tax Act- Section 122.3- Subsection 122.3(1) Activities of developing computer software must involve the use of engineering knowledge in order to be considered an engineering activity, and the provision of instruction and advice on computer programs and maintenance will not be qualified activities. ...

7 August 1992, T.I. 920376 (May 1993 Access Letter, p. 192, ¶C20-1145)-- summary under Subparagraph 20(1)(p)(ii) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(p)- Subparagraph 20(1)(p)(ii) S.20(1)(p)(ii) will apply to a moneylender that is in the process of winding-up in respect of loans or lending assets that become doubtful or are established to be uncollectible in the period before it is wound up but after it has ceased to solicit new business. ...

8 June 1993 T.I. (Tax Window, No. 32, p. 18, ¶2615)-- summary under Subsection 16.1(1) Summary Under Tax Topics- Income Tax Act- Section 16.1- Subsection 16.1(1) After the confirmation of Finance that it was not intended that an election under s. 16.1 should cause equipment not to qualify for an investment tax credit, RC on an administrative basis has adopted the position that Regulation 2902(b)(ii) will not apply to the leased equipment. ...

12 January 1993 T.I. (Tax Window, No. 20, p. 16, ¶2385)-- summary under Retiring Allowance Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Retiring Allowance When an employee ceases work due to retirement but pension benefits continue to accrue or normal employee benefits continue to be enjoyed by the individual, it is unlikely that employment has ceased, with the result that amounts received during this period would not be considered to be retiring allowances. ...

8 June 1993 T.I. (Tax Window, No. 32, p. 18, ¶2615)-- summary under Regulation 2902 Summary Under Tax Topics- Income Tax Regulations- Regulation 2902 After the confirmation of Finance that it was not intended that an election under s. 16.1 should cause equipment not to qualify for an investment tax credit, RC on an administrative basis has adopted the position that Regulation 2902(b)(ii) will not apply to the leased equipment. ...

(January- February 1993 Access Letter, p 36, ¶C248-123)-- summary under Retiring Allowance Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Retiring Allowance It is unlikely that employment has ceased where pension benefits continue to accrue or normal employee benefits continue to be enjoyed by the individual, even though he is not required to report to work. ...

5 January 1993 T.I. (Tax Window, No. 28, p. 15, ¶2402)-- summary under Paragraph 6(1)(b) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(b) Amounts received by employees pursuant to a Quebec regulation requiring construction contractors to pay a set amount per day to employees to cover the employees' cost of travelling between home and the work site are included in their income under s. 5(1), and are not allowances for travelling expenses within the meaning of s. 6(1)(b). ...

13 November 1992 T.I. 922953 (September 1993 Access Letter, p. 414, ¶C56-253)-- summary under Paragraph 56(1)(v) Summary Under Tax Topics- Income Tax Act- Section 56- Subsection 56(1)- Paragraph 56(1)(v) Where parents providing services as trustees or attendants receive disability payments on behalf of a disabled worker, such amounts will be included in the disabled worker's income under s. 56(1)(v), and will be deductible to the payor under s. 110(1)(f)(ii). ...

(April 1993 Access Letter, p. 146, ¶C109-128)-- summary under Qualified Small Business Corporation Share Summary Under Tax Topics- Income Tax Act- 101-110- Section 110.6- Subsection 110.6(1)- Qualified Small Business Corporation Share Paragraph (d) of the definition can have no application where there are only two corporations and one of the corporations (Holdco) has, as its only assets, shares and debt of a second corporation (Opco) which satisfies the 50% test at all times. ...