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Technical Interpretation - External summary

17 November 1992 T.I. 923120 (September 1993 Access Letter, p. 413, ¶C56-250) -- summary under Subsection 126(1)

17 November 1992 T.I. 923120 (September 1993 Access Letter, p. 413, ¶C56-250)-- summary under Subsection 126(1) Summary Under Tax Topics- Income Tax Act- Section 126- Subsection 126(1) Where a lump sum payment is received out of a foreign pension plan and rolled into an RRSP, the numerator under s. 126(1)(b)(i) will not be reduced by any deduction claimed under s. 60(j)(1) for an amount rolled into an RRSP because, under the sourcing rule in ss.4(1)(a) and 4(2), the payment is not reduced by the deduction under s. 60(j)(i). ...
Technical Interpretation - External summary

6 April 1993 T.I. (Tax Window), No. 30, p. 7, ¶2489) -- summary under Non-Capital Loss

6 April 1993 T.I. (Tax Window), No. 30, p. 7, ¶2489)-- summary under Non-Capital Loss Summary Under Tax Topics- Income Tax Act- Section 111- Subsection 111(8)- Non-Capital Loss Where a non-capital loss in a preceding year has been reinstated as the result of the carryback to that year of a net capital loss, the taxpayer will be required to comply with s. 152(6) in order to carry back the reinstated non-capital loss to a year preceding the loss application year. ...
Technical Interpretation - External summary

23 June 1993 T.I. (Tax Window, No. 32, p. 22, ¶2627) -- summary under Paragraph 6801(a)

23 June 1993 T.I. (Tax Window, No. 32, p. 22, ¶2627)-- summary under Paragraph 6801(a) Summary Under Tax Topics- Income Tax Regulations- Regulation 6801- Paragraph 6801(a) A deferred salary leave plan will cease to be a prescribed plan at the time that it is reasonable to assume that the conditions of the plan will not be fulfilled and could be subject to the salary deferral rules from its inception. ...
Technical Interpretation - External summary

24 February 1993 T.I. (Tax Window, No. 29, p. 15, ¶2439) -- summary under Section 87

24 February 1993 T.I. (Tax Window, No. 29, p. 15, ¶2439)-- summary under Section 87 Summary Under Tax Topics- Other Legislation/Constitution- Federal- Indian Act- Section 87 Income of a trust payable to an Indian generally will not be taxable if the trust property held for her benefit would be exempt from tax if held by her directly, or if the trustees reside on a reserve and a majority of the other relevant factors connect the trust to the reserve. ...
Technical Interpretation - External summary

15 June 1993 T.I. (Tax Window, No. 32, p. 12, ¶2606) -- summary under Private Health Services Plan

15 June 1993 T.I. (Tax Window, No. 32, p. 12, ¶2606)-- summary under Private Health Services Plan Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Private Health Services Plan A plan providing coverage for a partner of the same sex does not qualify as a private health services plan. ...
Technical Interpretation - External summary

15 June 1993 T.I. (Tax Window, No. 32, p. 9, ¶2601) -- summary under Paragraph 6(1)(a)

15 June 1993 T.I. (Tax Window, No. 32, p. 9, ¶2601)-- summary under Paragraph 6(1)(a) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a) Where a business is extended to take advantage of the lower airfare offered for a trip that is over a weekend, then provided the business trip was not extended to provide a vacation for the employee and the costs incurred were reasonable, a taxable benefit will not normally arise. ...
Technical Interpretation - External summary

10 February 1993 TI (Tax Window, No. 28, p. 17, ¶2409) -- summary under Timing

10 February 1993 TI (Tax Window, No. 28, p. 17, ¶2409)-- summary under Timing Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Timing Individual partners are permitted to deduct expenses relating to the business of a partnership that does not have a calendar fiscal period on either a calendar-year basis or on the basis of the partnership's fiscal year-end. ...
Technical Interpretation - External summary

22 January 1993 T.I. 9203635 (Tax Window, No. 27, p. 1, ¶2360) -- summary under Paragraph 12(1)(c)

22 January 1993 T.I. 9203635 (Tax Window, No. 27, p. 1, ¶2360)-- summary under Paragraph 12(1)(c) Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(1)- Paragraph 12(1)(c) A structured settlement agreement that provides for balloon payments which the injured person can elect in the future to take either as a lump sum or as a further series of periodic payments (whose terms would be determined at the time of making the election) will not comply with IT-365R2 and, therefore, will not be exempt from tax. ...
Technical Interpretation - External summary

22 January 1993 T.I. 9203635 (Tax Window, No. 27, p. 1, ¶2360) -- summary under Paragraph 56(1)(d)

22 January 1993 T.I. 9203635 (Tax Window, No. 27, p. 1, ¶2360)-- summary under Paragraph 56(1)(d) Summary Under Tax Topics- Income Tax Act- Section 56- Subsection 56(1)- Paragraph 56(1)(d) A structured settlement agreement that provides for balloon payments which the injured person can elect in the future to take either as a lump sum or as a further series of periodic payments (whose terms would be determined at the time of making the election) will not comply with IT-365R2 and, therefore, will not be exempt from tax. ...
Technical Interpretation - External summary

22 January 1993 T.I. 9203635 (Tax Window, No. 27, p. 1, ¶2360) -- summary under Exempt Receipts/Business

22 January 1993 T.I. 9203635 (Tax Window, No. 27, p. 1, ¶2360)-- summary under Exempt Receipts/Business Summary Under Tax Topics- Income Tax Act- Section 9- Exempt Receipts/Business A structured settlement agreement that provides for balloon payments which the injured person can elect in the future to take either as a lump sum or as a further series of periodic payments (whose terms would be determined at the time of making the election) will not comply with IT-365R2 and, therefore, will not be exempt from tax. ...

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