Search - 德国民法典第1993条

12 January 1993 T.I. (Tax Window, No. 28, p. 21, ¶2388)-- summary under Paragraph 251(1)(c) Summary Under Tax Topics- Income Tax Act- Section 251- Subsection 251(1)- Paragraph 251(1)(c) Where a widow is the sole beneficiary of her husband's estate and all the shares of a corporation previously owned by her husband are held by an unrelated trustee, she will be considered to have a right to those shares under s.251(5)(b)(i), with the result that that corporation will be considered to be related to a second corporation that is wholly-owned by her. ...

12 January 1993 T.I. (Tax Window, No. 28, p. 21, ¶2388)-- summary under Paragraph 251(5)(b) Summary Under Tax Topics- Income Tax Act- Section 251- Subsection 251(5)- Paragraph 251(5)(b) Where a widow is the sole beneficiary of her husband's estate and all the shares of a corporation previously owned by her husband are held by an unrelated trustee, she will be considered to have a right to those shares under s.251(5)(b)(i), with the result that that corporation will be considered to be related to a second corporation that is wholly-owned by her. ...

8 April 1993 T.I. (Tax Window, No. 30, p. 19, ¶2502)-- summary under Paragraph 55(3)(b) Summary Under Tax Topics- Income Tax Act- Section 55- Subsection 55(3)- Paragraph 55(3)(b) An acquisition of property will not normally be considered to have occurred in contemplation of a butterfly reorganization where the acquisition occurred in the ordinary course of the particular corporation's business and would have occurred irrespective whether the butterfly reorganization subsequently occurred, the structure and timing of the acquisition was not affected by butterfly-related considerations, and the acquisition was [not] conditional on completion of the butterfly transactions. ...

27 November 1992 T.I. 920738 (September 1993 Access Letter, p. 421, ¶C117-203)-- summary under Section 122.3 Summary Under Tax Topics- Income Tax Act- Section 122.3 A Canadian company that was a specified employer and that as part of its business contracted to provide the services of its employees to another Canadian company that had contracted with a foreign government to carry on an oil and gas exploration project in a foreign country, would be entitled to the credit if the other requirements of s. 122.3 were met. ...

28 January 1993 T.I. (Tax Window, No. 28, p. 9, ¶2403)-- summary under Business-Income Tax Summary Under Tax Topics- Income Tax Act- Section 126- Subsection 126(7)- Business-Income Tax Where, under French tax law, a Canadian-resident artistic loan-out corporation effectively is disregarded so that the artist is considered to be directly taxable, a French withholding tax of 15% on the gross income of the loan-out corporation will not give rise to a Canadian foreign tax credit because the artist is the only person legally liable for the French tax. ...

11 August 1992, T.I. 921396 (May 1993 Access Letter, p. 197, ¶C56-226)-- summary under Subsection 75(2) Summary Under Tax Topics- Income Tax Act- Section 75- Subsection 75(2) S.75(2) would apply if the transferor retains the power to veto distributions of property to beneficiaries or could select beneficiaries from a predetermined class. ...

19 May 1993 T.I. (Tax Window, No. 31, p. 5, ¶2512)-- summary under Subsection 146(4) Summary Under Tax Topics- Income Tax Act- Section 146- Subsection 146(4) The writing of naked call options (unlike the writing of covered call options) will be considered to be carrying on a business. ...

13 January 1993 External T.I. 5-923395-- summary under Paragraph 110(1)(d) Summary Under Tax Topics- Income Tax Act- 101-110- Section 110- Subsection 110(1)- Paragraph 110(1)(d) RC does not as a general rule express an opinion on the reasonableness of a method proposed to be used in arriving at the fair market value of a property at a particular point in time, and will become involved only after the fact if it considers the value assigned to the property to be unreasonable in the circumstances. ...

26 August 1992 Memorandum 921728 (April 1993 Access Letter, p. 139, ¶C56-222)-- summary under Paragraph 60(o) Summary Under Tax Topics- Income Tax Act- Section 60- Paragraph 60(o) Legal and accounting fees respecting a voluntary disclosure are not deductible under s. 60(o). ...

17 August 1992, T.I. 921353 (April 1993 Access Letter, p. 135, ¶C20-1141)-- summary under Subsection 12(3) Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(3) In order for the forgiveness of accrued interest owing by a non-arm's length person to be effective, there must be an amendment to the original agreement. ...