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7 October 2022 APFF Roundtable

Roundtable notes
In that case, an individual had earned income from self-employment during his 1993 taxation year, and had filed a proposal on September 3, 1993, which was homologated by the court on October 13 of the same year. In summary, the Quebec Court of Appeal concluded that the individual's tax debts for his 1993 taxation year should be considered a provable claim based on a proportional allocation of the debts for 1993 according to the number of days in the year before the date of the proposal and the period beginning on that date, on the grounds that the individual's tax debts had arisen as his income had been earned. ...

2 November 2023 APFF Roundtable

Roundtable notes
The Queen, [footnote: [1993] 4 S.C.R. 695] the purpose of a dividend is to be determined objectively on the basis of objective and subjective manifestations of the purpose behind the payment or receipt of the Dividend. ...

14 February 2001 CBA Roundtable

Roundtable notes
MISCELLANEOUS Q.40- Bare Trusts Effective January 20, 1993, the CCRA changed from requiring bare trusts to be registered for GST purposes to requiring the beneficial owners to be registered. TIB B-068 “Bare Trusts” indicated that there would be no interest or penalties if beneficial owners registered to comply with the new policy prior to June 1, 1993, provided the bare trust, who was previously registered, had already remitted the correct amount of net tax. ...

9 March 2006 CBA Roundtable

Roundtable notes
GST Memoranda 400-3-4 and 400-3-9, published before the legislation was amended in 1993 effective April 1991, both contemplate that a full ITC is available for “more than 50%” use of the property in commercial activities. ...

3 March 2005 CBA Roundtable

Roundtable notes
GST Memoranda 400-3-4 and 400-3-9, published before the legislation was amended in 1993 effective April 1991, both contemplate that a full ITC is available for “more than 50%” use of the property in commercial activities. ...