Search - 德国民法典第1993条

1 June 1993 Income Tax Severed Letter 930642A F- Qualified Investment-- summary under Paragraph 4900(1)(b) Summary Under Tax Topics- Income Tax Regulations- Regulation 4900- Subsection 4900(1)- Paragraph 4900(1)(b) Shares represented by an instalment receipt and that are pledged to a seller of shares to secure the obligation of the holder to pay the unpaid purchase price for the share will be a qualified investment provided the shares of the corporation are listed for trading on a prescribed stock exchange. ...

29 July 1993 Internal T.I. 9320007 F- Investment By Way of Contributed Surplus-- summary under Paragraph 20(1)(c) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c) "The deduction of interest should not be denied to a Canadian corporation that borrows funds to invest in a subsidiary, by way of contributed surplus provided the funds are to be used in a business to earn income and it is reasonable to expect that dividends will be earned by the Canadian corporation in the foreseeable future. ...

9 July 1993 External T.I. 9306605 F- Whether Corporation Can Make Donation Rather Than Estate-- summary under Subsection 15(1) Summary Under Tax Topics- Income Tax Act- Section 15- Subsection 15(1) Where a corporation makes a charitable donation on behalf of a deceased shareholder, there will be a shareholder benefit which (on the assumption that the estate was obligated to make the donation before it distributed property to the beneficiaries) would be included in the income of the estate rather than the beneficiary. ...

20 September 1993 Income Tax Severed Letter 9321275- Life Annuities-- summary under Capital Dividend Account Summary Under Tax Topics- Income Tax Act- Section 89- Subsection 89(1)- Capital Dividend Account S.245 potentially could apply to a back-to-back insurance strategy which provided for the purchase of a term life insurance policy providing a death benefit equal to the premium paid to acquire a life annuity, if the purpose of the arrangement was to provide an addition to the capital dividend account in circumstances where the death benefit could be considered a return of an investment. ...

2 December 1993 Income Tax Severed Letter 9313197- Moving Expenses—GST on New Home Purchase-- summary under Section 62 Summary Under Tax Topics- Income Tax Act- Section 62 GST paid on the purchase of a new home is not considered a tax "imposed on the transfer or registration of title" to a new residence as described in s. 62(3)(f) and, therefore, does not qualify as an eligible moving expense. ...

23 November 1993 External T.I. 9322405 F- SR & ED-- summary under Subsection 37(1) Summary Under Tax Topics- Income Tax Act- Section 37- Subsection 37(1) Where a non-resident company makes charges in the form of technical fees, royalties or licence fees to a Canadian taxpayer for the right to manufacture or produce a product developed as a result of SR&ED previously performed in Canada, this will not jeopardize the eligibility of the Canadian taxpayer for the ITC. ...

3 December 1993 External T.I. 9200995 F- Transfer of Farm Inventory to a Corporation-- summary under Other Summary Under Tax Topics- General Concepts- Fair Market Value- Other Where the market price of wheat is $2 per bushel but under a gross revenue insurance program a farmer is guaranteed a price of $4 per bushel, the fair market value of wheat inventory transferred to his corporation will be considered to be $2 per bushel. ...

8 December 1993 External T.I. 9332125 F- HAA 7209-1 Division of DPSP on Marriage Breakdown-- summary under Subsection 147(2) Summary Under Tax Topics- Income Tax Act- Section 147- Subsection 147(2) Funds in an DPSP cannot be split on a marriage breakdown given the prohibition against assignment in s. 147(2)(e). ...

3 December 1993 External T.I. 9200995 F- Transfer of Farm Inventory to a Corporation-- summary under Subsection 56(4) Summary Under Tax Topics- Income Tax Act- Section 56- Subsection 56(4) Where a farmer, who is guaranteed under the Gross Revenue Insurance Program ("GRIP") to receive a price of $4 per bushel of wheat, transfers his wheat inventory to a corporation at a time that he was already entitled to receive a GRIP amount, s. 56(4) would apply to include this amount in his income in the year of transfer. ...

8 November 1993 Income Tax Severed Letter 9332055- Expenses Prior to Mineral Resource Certification-- summary under Paragraph (f) Summary Under Tax Topics- Income Tax Act- Section 66.1- Subsection 66.1(6)- Canadian exploration expense- Paragraph (f) Once a mineral deposit is certified pursuant to paragraph (d)(i) of the definition of "mineral resource" in s. 248(1), the deposit will be considered to be a mineral resource for the purposes of determining a taxpayer's CEE, notwithstanding that the expenses may have been incurred prior to the date of certification. ...