Search - 德国民法典第1993条

22 March 1993 T.I. (Tax Window, No. 29, p. 12, ¶2443)-- summary under Subsection 104(4) Summary Under Tax Topics- Income Tax Act- 101-110- Section 104- Subsection 104(4) Where the will of the testator directs the executor and trustee to hold the residue of the estate in trust for the testator's child for life and on the child's death to divide the property into equal shares for the testator's grandchildren and to pay and transfer such property to another trustee, or to hold such property, in a separate trust for each grandchild, then in the absence of s. 104(5.8), the 21-year period referred to in s. 104(4)(b) will commence anew on the distribution to the grandchildren trusts. ...

20 May 1993 T.I. (Tax Window, No. 31, p. 3, ¶2509)-- summary under Paragraph 95(2)(a) (historical) Summary Under Tax Topics- Income Tax Act- Section 95- Paragraph 95(2)(a) (historical) Where funds are loaned by FA1 to FA2, which carries on business in the U.S. and, due to the application of the excess interest rule in s. 163(j) of the IRC, FA2 is unable to claim a current deduction for the interest paid to FA1, the full amount of the interest received will be active business income to FA1 and included in its earnings for purposes of Regulation 5907(1)(a)(ii). ...

20 May 1993 T.I. (Tax Window, No. 31, p. 3, ¶2509)-- summary under Paragraph 5907(2)(j) Summary Under Tax Topics- Income Tax Regulations- Regulation 5907- Subsection 5907(2)- Paragraph 5907(2)(j) Where funds are lent by FA1 to a second foreign affiliate (FA2) which carries on business in the U.S., and due to the application of the excess interest rule in s. 163(j) of the IRC, FA2 is unable to claim a current deduction for the interest paid to FA1, Regulation 5907(2)(j)(i) will not be applicable in computing the earnings of FA2 for the year the interest is paid because s. 163(j) only defers the deduction. ...

8 February 1993 T.I. (Tax Window, No. 29, p. 7, ¶2422)-- summary under Subsection 74.4(4) Summary Under Tax Topics- Income Tax Act- Section 74.4- Subsection 74.4(4) Where the grandfather of the taxpayer settles a trust of which the taxpayer is a beneficiary, and the taxpayer's father contributes shares of a corporation to the trust, the conditions in 74.4(4) will be met if the taxpayer has no other interest in the corporation, he is only entitled to the income and capital of the trust after his father's death and he does not receive or otherwise obtain the use of any of the income and capital of the trust while he remains a designated person in respect of his father. ...

18 January 1993 External T.I. 5-921647-- summary under Subsection 18(6) Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(6) Where a U.S. parent loans $100 to a wholly-owned Canadian subsidiary, and s. 18(4) applies to deny all of the interest charges of $10 payable on the first loan on the condition that the same amount be on-lent to a second wholly-owned subsidiary, RC will not apply s. 18(4) to deny the deduction by the second subsidiary of interest on the second loan. ...

5 February 1993 T.I. (Tax Window, No. 28, p. 3, ¶2411)-- summary under Subsection 256(1.4) Summary Under Tax Topics- Income Tax Act- Section 256- Subsection 256(1.4) S.256(1.4)(a) applies in a situation where the articles of incorporation or a shareholders' agreement for a corporation having three equal common shareholders (one of whom also owns all the preferred shares) provides that in the event a shareholders' meeting is called to consider a reorganization of the share capital, a winding-up of the corporation, or an amendment to the share provisions of the preferred shares, the preferred shares will be given the right to vote, with the result that the preferred shareholder would hold more than 50% of the votes. ...

18 January 1993 External T.I. 5-921718-- summary under Subsection 248(4) Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(4) A three-year second mortgage loan, bearing interest at 11% per annum, made by a non-resident to a Canadian partnership provided that on maturity the lender would receive, in addition to principal and interest, 10% of the increase in the value of the building, if any, over the three-year term as determined by independent appraisal. ...

1 April 1993 T.I. (Tax Window, No. 30, p. 20, ¶2500)-- summary under Paragraph 20(1)(e) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(e) Where there is an acquisition of control of a debtor and of its debt followed in the same day by an amalgamation of the debtor and the purchaser, then provided no election is made under s. 256(9), the amalgamation will be considered to occur on the same day and time as specified in the Certificate of Amalgamation. ...

8 January 1993 External T.I. 5-910367-- summary under Real Estate Summary Under Tax Topics- Income Tax Act- Section 9- Capital Gain vs. ...

29 January 1993 T.I. 9200395 (Tax Window, No. 27, p. 1, ¶2360)-- summary under Paragraph 12(1)(c) Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(1)- Paragraph 12(1)(c) Where a casualty insurer acquires an annuity contract to fund a series of periodic payments to compensate an injured party for lost income and acquires a second annuity contract providing for a series of periodic and balloon payments to fund future medical and personal care expenses, with both series of payments having a guarantee period and specified beneficiaries to whom the payments are directed in the event of the injured person's death before the end of the guarantee period, RC will require the first annuity contract to be non-commutable during the guarantee period or the life of the insured person. ...