Search - 德国民法典第1993条

1 June 1993 External T.I. 93061850- Prestations d'assurance-salaire-- summary under Paragraph 6(1)(f) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(f) benefits under wage loss insurance plan were taxable to employees because they had not fully borne the premiums (but s. 6(1)(f)(v) deductions available) CRA disagreed with the representation that all the premiums under a wage loss insurance plan required under the collective agreement were borne by the employees. ...

8 December 1993 Income Tax Severed Letter 9333680- Option Agreements—Non-arm's length Situations-- summary under Paragraph 69(1)(b) Summary Under Tax Topics- Income Tax Act- Section 69- Subsection 69(1)- Paragraph 69(1)(b) Where a company acquires from a person with whom it does not deal at arm's length an option to acquire property at a fixed price, s. 69(1)(b) "could be applied when the option is granted, if not granted at fair market value. ...

8 April 1993 Income Tax Severed Letter 9236345- Spousal Trust and Subsection 104(13.1) Designation-- summary under Subsection 104(13.1) Summary Under Tax Topics- Income Tax Act- 101-110- Section 104- Subsection 104(13.1) Where a spouse is entitled to receive all the income of a testamentary spousal trust but revokes in writing his or her right to receive such income in a given year, a valid designation may be made under s. 104(13.1). ...

11 May 1993 External T.I. 9302225 F- Active Business Carried on in Canada-- summary under Small Business Corporation Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Small Business Corporation "As a general rule a business that involves the sale or leasing of goods is usually carried on in the country where the corporation is resident, unless the business (or a part of it) is conducted by a virtually autonomous branch operation outside of Canada. ...

30 March 1993 External T.I. 9308305 F- Specified Leasing Property-- summary under Subsection 1100(1.11) Summary Under Tax Topics- Income Tax Regulations- Regulation 1100- Subsection 1100(1.11) "When a corporation derives revenue from the leasing of a vessel on a 'time-charter' basis (i.e., the owner provides all services including fuel, a captain, crew, provisions, etc., necessary to operate the vessel), such revenue would not normally be regarded as rent, royalty or leasing revenue. ...

2 June 1993 Income Tax Severed Letter 9301835- At-risk Amount—Partnership General-- summary under Paragraph 96(2.2)(d) Summary Under Tax Topics- Income Tax Act- Section 96- Subsection 96(2.2)- Paragraph 96(2.2)(d) The amount of reduction under s. 96(2.2)(d) at any particular time to a limited partner's at-risk amount as a result of limited recourse borrowings obtained by the partner will be the amount of the limited recourse borrowings outstanding at that time. ...

28 June 1993 Income Tax Severed Letter 9307365- Directors Liability Insurance-- summary under Paragraph 6(1)(a) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a) A taxable benefit will not be conferred on a director or officer of a corporation as a result of the corporation paying insurance premiums or her receiving a settlement from the insurance company where the risks covered by the policy are inherent and normal occurrences in carrying out the duties of the insured. ...

22 July 1993 External T.I. 9313855 F- Connected Corporations-- summary under Subsection 186(4) Summary Under Tax Topics- Income Tax Act- Section 186- Subsection 186(4) "The existence of a shareholders' agreement or a voting trust which dictates the manner in which the shares are to be voted will not disqualify the shares from satisfying the 'full voting rights' requirement of subparagraph 186(4)(b)(i).... ...

19 August 1993 External T.I. 9322075 F- Capitalization of Interest-- summary under Subsection 21(3) Summary Under Tax Topics- Income Tax Act- Section 21- Subsection 21(3) Where an amount is expended in respect of borrowed money to acquire depreciable property in a year and an amount is also expended in the following year to acquire additional depreciable property and an election is made in respect of the initial year pursuant to s. 21(1), the failure to elect under s. 21(1) with respect to the second year expenditure should not preclude an election under s. 21(3) for years subsequent to the initial year. ...

21 October 1993 Income Tax Severed Letter 9325325- Mortgage Pay-out Penalties-- summary under Subparagraph 40(1)(a)(i) Summary Under Tax Topics- Income Tax Act- Section 40- Subsection 40(1)- Paragraph 40(1)(a)- Subparagraph 40(1)(a)(i) loan penalty on sale Where penalty payments are made in order to pay off a mortgage, or reduce the interest rate on a mortgage, prior to the sale of the mortgaged capital property, the payment will be considered to have been made or incurred for the purpose of making the disposition and s. 40(1)(a)(i) will be applicable. ...