Search - 德国民法典第1993条

No. 142 "Paid-Up Capital Foreign Currency Shares"; May 1993 Access Letter, p. 230)-- summary under Paid-Up Capital Summary Under Tax Topics- Income Tax Act- Section 89- Subsection 89(1)- Paid-Up Capital Because where a transaction is on capital account, the Canadian dollar value of the transaction is calculated at the exchange rate prevailing at the time of the transaction, the paid-up capital of shares maintained in a foreign currency is determined by converting the foreign currency amount to Canadian currency at the exchange rate at the time the shares were issued. ...

15 February 1993 T.I. 9231345 [loan from pension fund shareholder]-- summary under Subparagraph 149(1)(o.2)(iii) Summary Under Tax Topics- Income Tax Act- Section 149- Subsection 149(1)- Paragraph 149(1)(o.2)- Subparagraph 149(1)(o.2)(iii) loan from pension fund shareholder Does a non-interest bearing demand loan by a pension plan to a subsidiary corporation to facilitate the transfer of monies into and out of the corporation comply with s. 149(1)(o.2)(iii)(B)? ...

20 October 1992 T.I. 922116 (September 1993 Access Letter, p. 418, ¶C111-055)-- summary under Rules Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 27A- Rules A non-resident of Canada who was resident in England but not domiciled there for tax purposes, and who on her death in England is subject to English estate duty to a deemed disposition under s. 70(5) on shares of a private Canadian corporation and would not be considered to be taxed in the U.K. by reference to an amount that was remitted to or received in the U.K. as a result of such deemed disposition. ...

20 October 1992 T.I. 922116 (September 1993 Access Letter, p. 418, ¶C111-055)-- summary under Article 29 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 29 A non-resident of Canada who was resident in England but not domiciled there for tax purposes, and who on her death in England is subject to English estate duty to a deemed disposition under s. 70(5) on shares of a private Canadian corporation and would not be considered to be taxed in the U.K. by reference to an amount that was remitted to or received in the U.K. as a result of such deemed disposition. ...

6 April 1993 T.I. (Tax Window, No. 30, p. 5, ¶2493)-- summary under Subsection 50(1) Summary Under Tax Topics- Income Tax Act- Section 50- Subsection 50(1) Anderson v. ...

7 August 1992 T.I. 921506 (May 1993 Access Letter, p. 197, ¶C56-227; Tax Window, No. 23, p. 18, ¶2126)-- summary under Subsection 107(4.1) Summary Under Tax Topics- Income Tax Act- 101-110- Section 107- Subsection 107(4.1) S.107(4.1) does not apply where a trust distributes property back to the settlor. ...

14 July 1992, T.I. 921748/921721 (March 1993 Access Letter, p. 77, ¶C117-181)-- summary under Subsection 118.6(1) Summary Under Tax Topics- Income Tax Act- Section 118.6- Subsection 118.6(1) In response to an inquiry as to whether the credit was available for participation in the Canadian Job Strategies Program or the Ontario Basic Skills Program it was noted that a student participating in a program which was available to the public at large would not be considered to have received the benefit solely by reason of tuition not being charged for that program. ...

18 January 1993 External T.I. 5-921718-- summary under Taxpayer Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Taxpayer A loan by a non-resident individual to a Canadian partnership secured by a second mortgage on a building owned by the partnership, that provided for the payment on maturity of 10% of the appreciation in value of the building in addition to interest at a rate of 11% per annum, would constitute an interest in real property situated in Canada for purposes of s. 115(1)(b) under the broad definition in s. 115(3). ...

25 August 1992, T.I. 921458 (April 1993 Access Letter, p. 144, C82-113)-- summary under Subsection 87(4) Summary Under Tax Topics- Income Tax Act- Section 87- Subsection 87(4) The position in IT-474R, that s. 87(4) will not be applied where an amalgamation agreement provides that the preferred and common shares of a predecessor corporation are to be converted to preferred shares and common shares of the amalgamated corporation, will also prevail in the case of a short-form amalgamation even though in such instance the conversion takes place pursuant to the governing corporate legislation rather than pursuant to an amalgamation agreement. ...

6 November 1992 T.I. 922332 (September 1993 Access Letter, p. 425, ¶C248-142)-- summary under Article 22 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 22 Where a Canadian employee of a U.S. company was a deemed resident of Canada under s. 250(1)(a) but was a U.S. resident under the tie-breaker rule in paragraph 2 of Article IV of the Canada-U.S. ...