Search - 德国民法典第1993条

16 December 1993 Income Tax Severed Letter 9320395- Employee Pay-All Accident Insurance Plans-- summary under Paragraph 6(1)(f) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(f) "The issue of whether or not an employee-pay-all plan exists is not determined by considering who paid the related premiums. ...

16 December 1993 Income Tax Severed Letter 9325635- Foreign Affiliate Deemed Active Business Income-- summary under Subparagraph 95(2)(a)(i) Summary Under Tax Topics- Income Tax Act- Section 95- Subsection 95(2)- Paragraph 95(2)(a)- Subparagraph 95(2)(a)(i) Subparagraph 95(2)(a)(i) will apply to interest income received by a Wyoming limited liability company (that is 50% owned by two arm's length Canadian-resident corporations) on a U.S. state bond issue the proceeds of which were used by the state to finance the construction of a manufacturing plant which is leased to a manufacturing partnership that also is indirectly owned on a 50/50 basis. ...

1993 Internal T.I. 9325537 F- Election Under Sub-- summary under Disposition Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Disposition "A disposition takes place when a share is cancelled during the process of a voluntary dissolution of a corporation pursuant to clause 54(c)(ii)(A) of the Act. ...

23 December 1993 External T.I. 9326885 F- The Application of Section 84.1 of the Income Tax Act-- summary under Subsection 84.1(1) Summary Under Tax Topics- Income Tax Act- Section 84.1- Subsection 84.1(1) RC's practice is to apply s. 84.1 where the conditions for its application are present given that its provisions do not give RC any administrative discretion in its application. ...

28 April 1993 Internal T.I. 9301657 F- Franchise Royalty Income- Active Business-- summary under Income of the Corporation for the Year From an Active Business Summary Under Tax Topics- Income Tax Act- Section 125- Subsection 125(7)- Income of the Corporation for the Year From an Active Business Discussion of whether lump sum payments received by a franchisor from its franchisees are income from an active business. ...

15 February 1993 External T.I. 9334215 F- Travel Expenses- Rental Property-- summary under Paragraph 18(1)(h) Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(h) RC is prepared to allow the deduction of reasonable motor vehicle expenses incurred by an individual who owns only one rental property where the rental property is located in her general area, she does part or all of the necessary repairs and maintenance on the property, and she incurs the expenses to transport tools and materials to the property. ...

28 April 1993 Income Tax Severed Letter 9312026- Retiring Allowance Employment Standards Act-- summary under Paragraph 153(1)(a) Summary Under Tax Topics- Income Tax Act- Section 153- Subsection 153(1)- Paragraph 153(1)(a) Where an employee who is laid off but wants to retain rights to be recalled requests that amounts that otherwise would be paid to him as severance pay and/or termination pay be held by the Director of the Employment Standards Branch, no withholding should be made by the employer with respect to those payments. ...

1993 Administrative Letter 9336656 F- Paragraph 5000(1) of the Income Tax Regulations-- summary under Subsection 5000(1) Summary Under Tax Topics- Income Tax Regulations- Regulation 5000- Subsection 5000(1) In response to an expressed concern that a trust or corporation could inadvertently have excess foreign property where it undertook to simultaneously acquire or dispose of more than one property but had to record the transactions at different times because of the way the transactions were actually processed, RC indicated that although the wording of the regulation was clear (the 20% limitation could not be exceeded even for a moment), it recognized that there may be reason to provide relief where simultaneously initiated transactions are recorded at different times due solely to the application of routine procedures. ...

19 May 1993 External T.I. 9308945 F- Qualified Investments- Put and Call Options-- summary under Subsection 146(4) Summary Under Tax Topics- Income Tax Act- Section 146- Subsection 146(4) writing of puts is an acceptable activity Regarding the writing of puts on shares by an RRSP, RC stated: The writing of a put option represents an agreement to purchase shares if the person who holds the option exercises his right to sell within a specified time. ...

2 February 1993 T.I. (Tax Window, No. 28, p. 5, ¶2414)-- summary under Subsection 55(2) Summary Under Tax Topics- Income Tax Act- Section 55- Subsection 55(2) Amounts actually expended but not deductible for tax purposes (e.g., 20% of entertainment expenses), and amounts actually expended but deferred or capitalized for tax purposes (e.g., contributions of an employer to an employee benefit plan pursuant to s. 18(1)(o) or amounts capitalized under s. 18(2)) cannot be included in safe income on hand until such time, if any, as they are deducted for tax purposes. ...