Search - 德国民法典第1993条

20 October 1993 External T.I. 9323775 F- Capital Account and Life Insurance Proceeds in Trust-- summary under Capital Dividend Account Summary Under Tax Topics- Income Tax Act- Section 89- Subsection 89(1)- Capital Dividend Account In order for life insurance proceeds to be included in the capital dividend account of a corporation, the proceeds must be considered to be received by the corporation. ...

5 November 1993 External T.I. 9320085 F- 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) Respecting guarantees by the Province of Saskatchewan of loans made to farmers where the Province did not waive its subrogation rights, the Directorate stated that provided the loans were not forgivable loans and: "Upon the honouring of a guarantee the amount paid by the Province becomes unconditionally repayable to the Province, the granting or the honouring of a guarantee under this program would generally not, in and by themselves, give rise to an amount which would constitute a [farm support payment]. ...

25 November 1993 Income Tax Severed Letter 9323577- Interest Costs on Bridge Financing upon Relocation-- summary under Subsection 15(2) Summary Under Tax Topics- Income Tax Act- Section 15- Subsection 15(2) RC's policy is that an employee will not be subject to a taxable benefit for the interest costs associated with bridge financing arrangements respecting the pending relocation of an employee where "all reasonable efforts" have been made to sell the employee's previous residence. ...

3 December 1993 External T.I. 9323925 F- General Comments on a Flex Plan-- summary under Paragraph 6(1)(a) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a) Although a benefit which will be non-taxable if offered outside a flexible benefit plan will ordinarily retain its non-taxable status if it is offered as an option under the plan, in order to maintain the non-taxable status of such benefits, any option to receive cash in exchange for the "flex credits" could only be available pursuant to an irrevocable election made before the beginning of the plan year and not as an option within a particular option or plan. ...

17 February 1993 Income Tax Severed Letter 9226895 F- Pertes-liquidation-- summary under Paragraph 88(1.1)(f) Summary Under Tax Topics- Income Tax Act- Section 88- Subsection 88(1.1)- Paragraph 88(1.1)(f) making 88(1.1)(f) election re loss from preceding taxation year of sub A subsidiary realized losses in its two taxation years preceding its winding-up. ...

2 December 1993 Income Tax Severed Letter 933330A F- Non-Resident Exercises Stock Option (4093-U5-100-15)-- summary under Article 15 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 15 Stock option benefits arising to an individual in respect of his Canadian employment after he ceased to be employed and while a resident of the U.S. would be subject to tax under s. 115(1)(a)(i) of the Act, without Article XV.1 of the Canada-U.S. ...

3 May 1993 External T.I. 9236395 F- Safe Income and Part IV Tax-- summary under Subsection 55(2) Summary Under Tax Topics- Income Tax Act- Section 55- Subsection 55(2) Where X owns 20% of the shares of Opco having a safe income of $100 and a fair market value of $125, and transfers all of such shares to a new corporation ("Newco") on a rollover basis in exchange for shares of Newco, and Opco then redeems the shares held by Newco for $125 giving rise to a deemed dividend of $125, Newco will not be able to treat itself as having received a safe income dividend of $100 (assuming the appropriate designation under s. 55(5)(f)), and a further separate dividend of$25 subject to Part IV tax, if the payment of the deemed dividend by Opco triggers Part IV tax on $25 of that dividend deemed to be received by Newco: "It is our view that to the extent that a dividend refund arises in respect of tax paid on the investment income earned by a corporation which pays a dividend (the "payer corporation"), such income would, on an after tax basis, have been included in the calculation of the safe income of the payer corporation. ...

19 May 1993 External T.I. 9308945 F- Qualified Investments- Put and Call Options-- summary under Paragraph (a) Summary Under Tax Topics- Income Tax Act- Section 204- Qualified Investment- Paragraph (a) writing of puts is an acceptable RRSP activity/ cash held to cover the obligation may qualify Regarding the writing of puts on shares by an RRSP, RC stated: Where an RRSP is required to leave cash on deposit (margin) with a broker to cover the possible exercise of the option by the option holder to purchase the shares from the RRSP, such cash may or may not be a qualified investment. ...