Search - 德国民法典第1993条

29 January 1993 T.I. 9200395 (Tax Window, No. 27, p. 1, ¶2360)-- summary under Paragraph 56(1)(d) Summary Under Tax Topics- Income Tax Act- Section 56- Subsection 56(1)- Paragraph 56(1)(d) 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. ...

29 January 1993 T.I. 9200395 (Tax Window, No. 27, p. 1, ¶2360)-- summary under Exempt Receipts/Business Summary Under Tax Topics- Income Tax Act- Section 9- Exempt Receipts/Business 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. ...

29 January 1993 T.I. 9200395 (Tax Window, No. 27, p. 1, ¶2360)-- summary under Expense Reimbursement Summary Under Tax Topics- Income Tax Act- Section 9- Expense Reimbursement 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. ...

14 December 1993 Income Tax Severed Letter 9318147- Bad Debt Deduction for Part of a Loan-- summary under Subparagraph 20(1)(p)(ii) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(p)- Subparagraph 20(1)(p)(ii) part write-down is permitted CRA reviewed the older jurisprudence and noted: From a review of the foregoing caselaw, only Hogan and Wesco have held that a part bad debt deduction is possible under (now) paragraph 20(1)(p) of the Act, and Hogan did not deal with one loan, but rather with two debts arising from separate transactions between the same debtor and creditor. ...

30 March 1993 Income Tax Severed Letter 9329425- Bene Ownership of P/R Separate from Ownership of Farm-- summary under Ownership Summary Under Tax Topics- General Concepts- Ownership cannot transfer beneficial interest of portion of land that has not received severance approval In finding that an individual holding farm land would not be able to transfer ownership of the entire property other than beneficial ownership of the housing unit on one acre to a corporation under s. 85(1) in circumstances where a severance of the housing unit and one acre of land from the rest of the property could not be obtained, RC stated that "two essential elements of 'ownership' in the context of the principal residence are the right of alienation and the right of possession. ...

8 April 1993 Internal T.I. 9238487 F- Trust Money in Dispute-- summary under Paragraph 12(1)(c) Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(1)- Paragraph 12(1)(c) interest income in litigation trust is taxable to trust if no waivers issued Where the litigants and the trustee of a litigation trust have not submitted waivers for each year, income earned by the trust on the trust funds will not be payable to the beneficiaries because the entitlement of the litigants to the funds would not yet be determined. ...

6 April 1993 External T.I. 9301815 F- HA7988 Foreign Tax Credit- Member of Partnership-- summary under Business-Income Tax Summary Under Tax Topics- Income Tax Act- Section 126- Subsection 126(7)- Business-Income Tax Where a U.S. partnership in which a Canadian partnership holds a 99.9% interest pays U.S. corporate income tax (as a result of being taxed for U.S. purposes as a corporation) and also withholds U.S. taxes on distributions made to the Canadian partner, the business and non-business income taxes paid by the partnership will be allocated on a pro-rata basis to the partners for purposes of s. 126, and the withholding taxes paid on the distribution of after-tax profit will be considered to be business income tax provided that the profits are considered to be business income as opposed to income from property. ...

26 May 1993 Income Tax Severed Letter 9314085- Lease Inducement Payments-- summary under Improvements v. ...

7 June 1993 External T.I. 9308775- Bien locatif-- summary under Subsection 13(5) Summary Under Tax Topics- Income Tax Act- Section 13- Subsection 13(5) transfer to separate class when business-use building commenced to be rented pending its sale Corporation ABC use various buildings in the same business and which are part of the same CCA class. ...

19 August 1993 External T.I. 9322075 F- Capitalization of Interest-- summary under Subsection 21(1) Summary Under Tax Topics- Income Tax Act- Section 21- Subsection 21(1) Where money is borrowed to repay accrued interest on debt that was incurred to acquire depreciable property, interest on such further borrowing will not qualify for purposes of s. 21(1) as being in respect of borrowed money used to acquire the depreciable property or as being in respect of an amount payable for such property. ...