Search - 德国民法典第1993条

22 January 1993 T.I. 9203635 (Tax Window, No. 27, p. 1, ¶2360)-- summary under Expense Reimbursement Summary Under Tax Topics- Income Tax Act- Section 9- Expense Reimbursement 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. ...

1 February 1993 T.I. (Tax Window, No. 28, p. 11, ¶2386)-- summary under Subsection 10(1) Summary Under Tax Topics- Income Tax Act- Section 10- Subsection 10(1) Where the cost of developing a golf course situate in the middle of a residential development exceeds its estimated fair market value, the developer will not be able to add such excess to the cost of the surrounding residential lots even though the purpose of developing the golf course was to increase the value of those lots. ...

22 January 1993 T.I. (Tax Window, No. 28, p. 10, ¶2379)-- summary under Paragraph 256(7)(a) Summary Under Tax Topics- Income Tax Act- Section 256- Subsection 256(7)- Paragraph 256(7)(a) Where the articles of a corporation provide that the voting rights associated with a particular block of voting shares (representing more than 50% of the total) lapse on the holder's death, the spouse holding the balance of the shares will acquire control when the taxpayer dies, assuming this arrangement is legally effective. ...

1 February 1993 T.I. (Tax Window, No. 28, p. 11, ¶2386)-- summary under Computation of Profit Summary Under Tax Topics- Income Tax Act- Section 9- Computation of Profit Where the cost of developing a golf course situate in the middle of a residential development exceeds its estimated fair market value, the developer will not be able to add such excess to the cost of the surrounding residential lots even though the purpose of developing the golf course was to increase the value of those lots. ...

19 November 1992 Memorandum 923036 (September 1993 Access Letter, p. 424, ¶C144-240)-- summary under Subsection 147(2) Summary Under Tax Topics- Income Tax Act- Section 147- Subsection 147(2) Although a pension plan could have two separate trusts relating to two sets of defined benefit provisions, if the plan was adequately funded an employer would not be able to make a contribution on the basis that assets relating to one of the defined benefit provisions were deficient. ...

15 July 1992 T.I. 920963 (January- February 1993 Access Letter, p. 11, ¶C9-255)-- summary under Outstanding Debts to Specified Non-Residents Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(5)- Outstanding Debts to Specified Non-Residents Given the breadth of s. 18(5)(a)(i)(A)(II), the thin capitalization rules will apply to loans made by a U.S. subsidiary to a Canadian parent corporation that is controlled by related Canadian resident individuals, or to a loan made by a U.S. subsidiary to a Canadian subsidiary of a Canadian parent. ...

18 June 1993 T.I. (Tax Window, No. 32, p. 10, ¶2603)-- summary under Remuneration Summary Under Tax Topics- Income Tax Regulations- Regulation 100- Subsection 100(1)- Remuneration A plan under which sick leave benefits to which an employee is entitled under the terms of an employment contract or collective agreement are paid to her through an employee benefit trust will be considered to give rise to salary or wages and, therefore, will be subject to the usual deductions for UIC and CPP. ...

11 March 1993, T.I. (Tax Window, No. 30, p. 13, ¶2465)-- summary under Paragraph 6(1)(a) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a) Where an employee is required to work at least three hours of overtime in a day, public transportation is not available or the physical safety of the employee is at risk at the time of travel, and the occurrence of such overtime is occasional, RC will not treat reimbursements for the cost of the employee's meals and travel (e.g., a mileage allowance) to be a taxable benefit. ...

2 December 1993 T.I. 933266 (C.T.O. "Adjustments to ACB of Section 7 Shares")-- summary under Subsection 7(1.5) Summary Under Tax Topics- Income Tax Act- Section 7- Subsection 7(1.5) S.7(1.5) will apply where an employee elects under s. 85(1) to be deemed to receive proceeds of disposition of the share in excess of its ACB. ...

15 January 1993 T.I. (Tax Window, No. 28, p. 23, ¶2371)-- summary under Disposition Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Disposition Where a non-resident co-tenant of Ontario real property transfers her interest in the property to a non-resident revocable trust, retaining for herself a life interest in the revocable trust, there will be a change in the beneficial ownership of the property, with the result that the exemption in s. 54(c)(b) will not be available. ...