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Miscellaneous summary

27 October 1993 Income Tax Severed Letter 9319925 - Farm Support Payments -- summary under Paragraph 12(1)(x)

27 October 1993 Income Tax Severed Letter 9319925- Farm Support Payments-- summary under Paragraph 12(1)(x) Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(1)- Paragraph 12(1)(x) inclusion re forgivable loan at time of advance A loan from the Agricultural Credit Corporation of Saskatchewan generally would be regarded as a forgivable loan and, therefore, as assistance "to the extent that the lender is committed to forgive the loan if certain conditions are met by the borrower. ...
Miscellaneous summary

22 November 1993 Income Tax Severed Letter 9323365 - Non-profit Organization—Terminal Losses -- summary under Subsection 149(10)

22 November 1993 Income Tax Severed Letter 9323365- Non-profit Organization—Terminal Losses-- summary under Subsection 149(10) Summary Under Tax Topics- Income Tax Act- Section 149- Subsection 149(10) Where an exempt corporation has depreciable property at the time it ceases to be an exempt corporation, and it realizes a terminal loss pursuant to s. 149(10)(b), it will be able to claim that amount in a future year only to the extent it could not be deducted in the year ending at the time of the change of status or as a non-capital loss in the three preceding years. ...
Technical Interpretation - External summary

2 December 1993 External T.I. 9321035 F - Taxation of GST and Other Rebates -- summary under Paragraph 12(1)(x)

2 December 1993 External T.I. 9321035 F- Taxation of GST and Other Rebates-- summary under Paragraph 12(1)(x) Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(1)- Paragraph 12(1)(x) The Ontario Farm Tax Rebate (entailing a rebate of 75% of property taxes paid on eligible farm land and out-buildings by eligible owners) is required to be included in income under s. 12(1)(x) to the extent it is not applied to reduce the expense for taxes otherwise deductible in the year. ...
Miscellaneous summary

30 November 1993 Income Tax Severed Letter 9322965 - Executor's Year—Loss Carryback to Year of Death Return -- summary under Subsection 164(6)

30 November 1993 Income Tax Severed Letter 9322965- Executor's Year—Loss Carryback to Year of Death Return-- summary under Subsection 164(6) Summary Under Tax Topics- Income Tax Act- Section 164- Subsection 164(6) Re whether prior to (1) the anniversary of the death of the deceased and (2) the winding-up of the estate, the executor has the right to wind-up a corporation, thereby accessing the loss under s. 164(6). ...
Miscellaneous summary

3 December 1993 Income Tax Severed Letter 9326586 - Allowances Paid by CIDA to Foreign Students and Trainees -- summary under Paragraph 56(1)(n)

3 December 1993 Income Tax Severed Letter 9326586- Allowances Paid by CIDA to Foreign Students and Trainees-- summary under Paragraph 56(1)(n) Summary Under Tax Topics- Income Tax Act- Section 56- Subsection 56(1)- Paragraph 56(1)(n) Amounts paid to individuals from developing countries in order to come to Canada to attend school full-time (usually for a period of 1- 3 years) would be considered taxable income under s. 56(1)(n) to the extent the amount received exceeds $500. ...
Miscellaneous summary

3 December 1993 Income Tax Severed Letter 9324577 - Automobile Allowance—Less than Reasonable Amount? -- summary under Subparagraph 6(1)(b)(vii.1)

3 December 1993 Income Tax Severed Letter 9324577- Automobile Allowance—Less than Reasonable Amount? ...
Miscellaneous summary

30 November 1993 Income Tax Severed Letter 9327165 - Vested Indefeasibly -- summary under Subsection 70(6)

30 November 1993 Income Tax Severed Letter 9327165- Vested Indefeasibly-- summary under Subsection 70(6) Summary Under Tax Topics- Income Tax Act- Section 70- Subsection 70(6) In determining whether a by-sell agreement in a shareholders' agreement would result in shares not be considered to vest indefeasibly in the spouse, it would be necessary to determine if any of the terms of the shareholders' agreement could be considered a condition subsequent or a determinable limitation set out in the grant, as discussed in Boger Estate, 93 DTC 5276 (FCA). ...
Miscellaneous summary

2 December 1993 Income Tax Severed Letter 933330A F - Non-Resident Exercises Stock Option (4093-U5-100-15) -- summary under Subparagraph 115(1)(a)(i)

2 December 1993 Income Tax Severed Letter 933330A F- Non-Resident Exercises Stock Option (4093-U5-100-15)-- summary under Subparagraph 115(1)(a)(i) Summary Under Tax Topics- Income Tax Act- Section 115- Subsection 115(1)- Paragraph 115(1)(a)- Subparagraph 115(1)(a)(i) Where a U.S. ...
Miscellaneous summary

2 December 1993 Income Tax Severed Letter 9333306 - Non-resident Exercised a Stock Option -- summary under Article 15

2 December 1993 Income Tax Severed Letter 9333306- Non-resident Exercised a Stock Option-- summary under Article 15 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 15 Where a U.S. resident exercises employee stock options issued to him by a U.S. public company while he was employed in Canada by a Canadian subsidiary, the resulting benefit will not be considered to be borne by the Canadian subsidiary for purposes of the Canada-U.S. ...
Miscellaneous summary

16 December 1993 Income Tax Severed Letter 9323725 - Same Sex Partner Coverage for Health Care Plan -- summary under Paragraph 6(1)(a)

16 December 1993 Income Tax Severed Letter 9323725- Same Sex Partner Coverage for Health Care Plan-- summary under Paragraph 6(1)(a) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a) The type of expenses which may be provided under a private health services plan are limited to those which qualify as medical expenses for purposes of the credit in s. 118.2(2) and, therefore, are limited to expenses incurred in respect of an individual, the individual's spouse or a dependant of the individual. ...

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