Search - 德国民法典第1993条

3 December 1993 External T.I. 9200995 F- Transfer of Farm Inventory to a Corporation-- summary under Subsection 85(1) Summary Under Tax Topics- Income Tax Act- Section 85- Subsection 85(1) Since the entitlement of a farmer under a gross revenue insurance program constitutes an account receivable to him that relates to the farming business carried on by him, it is on income account and is not a capital property to him. ...

3 December 1993 External T.I. 9200995 F- Transfer of Farm Inventory to a Corporation-- summary under Account Receivable Summary Under Tax Topics- Income Tax Act- Section 9- Capital Gain vs. ...

10 December 1993 Income Tax Severed Letter 9333055- Witholding Tax Exemption-- summary under Subparagraph 212(1)(b)(vii) Summary Under Tax Topics- Income Tax Act- Section 212- Subsection 212(1)- Subparagraph 212(1)(b)(vii) "In a situation where interest is computed by reference to dividends paid or payable to shareholders of any class of shares of the capital stock of a corporation, the interest shall be deemed not to be interest for purposes of subparagraph 212(1)(b)(vii) of the Act, by virtue of the postamble thereto, notwithstanding that the dividend component of a particular formula at the time of payment of interest is nil. ...

1993 Administrative Letter 9334736 F- Employer Reimburse GST on New Home Upon Relocation-- summary under Paragraph 6(1)(a) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a) Since the GST payable on the purchase of a new home forms part of the cost of that new asset, any reimbursement thereof by the employer in connection with an employee relocation will be included in income in the same manner as other costs of acquiring a new residence, such as decorating, appraisal fees, new home warranty fees and finder's fees. ...

16 December 1993 Income Tax Severed Letter 9316105- Remainder Interest in Land-- summary under Subsection 73(3) Summary Under Tax Topics- Income Tax Act- Section 73- Subsection 73(3) A remainder interest in land is "land" for purposes of s. 73(3) if the requirements in IT-268R3, para. 9 are satisfied and, if all other conditions under that subsection are met, the provisions of s. 73(3) will apply on its transfer and the provisions of s. 43.1(1) will not. ...

17 December 1993 Income Tax Severed Letter 9323875- Specified Leasing Property Rules-- summary under Subsection 1100(1.11) Summary Under Tax Topics- Income Tax Regulations- Regulation 1100- Subsection 1100(1.11) "The circumstances of a particular fact situation will determine whether a sublease causes the property to become 'specified leasing property'. ...

1993 External T.I. 9321175 F- Transfer of Farm Property-- summary under Subsection 73(3) Summary Under Tax Topics- Income Tax Act- Section 73- Subsection 73(3) It is not necessary that a particular asset be used in farming at a point in time immediately prior to the transfer. ...

23 December 1993 Internal T.I. 9335957 F- Overseas Employment Tax Credit-Subcontractor (7070-7)-- summary under Subsection 122.3(1) Summary Under Tax Topics- Income Tax Act- Section 122.3- Subsection 122.3(1) Employees of a sub-contractor may qualify for the credit notwithstanding that the sub-contractor itself is not carrying on a qualified activity provided that the employees' duties are performed outside Canada in connection with a contract under which the sub-contractor carries on business outside Canada with respect to a qualified activity (i.e., of the main contractor). ...

9 February 1993 T.I. (Tax Window, No. 29, p. 3 ¶2436)-- summary under Small Business Corporation Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Small Business Corporation Mortgages taken back by a developer in order to facilitate sales may initially be assets used in an active business, but will become investments if retained for more than a short period. ...

30 November 1992 T.I. 923168 (September 1993 Access Letter, p.423, ¶C144-238)-- summary under Subsection 146(8) Summary Under Tax Topics- Income Tax Act- Section 146- Subsection 146(8) Bonus interest payments paid by a credit union directly to the annuitant of an RRSP would be included in the annuitant's income under s. 146(8). ...