Search - 德国民法典第1993条

This Court granted leave to appeal from that decision:  [1993] 1 S.C.R. vii.                      ...

Berg, [1993] 2 S.C.R. 353, at p. 371.  As Professor Sullivan has wisely observed, even when the broad purposes of legislation are clear, “it does not follow that the unqualified pursuit of those purposes will give effect to the legislature’s intention”: R. ...

R. (1993), [1994] 1 C.T.C. 40 (S.C.C.), is clear that if the expenses are business in nature, instead of personal, the test for deductibility may be met by showing the expense satisfied a need of the company. ...

Canada, [1993] 4 S.C.R. 695, may be summarized as follows:- The interpretation of tax legislation should follow the ordinary rules of interpretation;- A legislative provision should be given a strict or liberal interpretation depending on the purpose underlying it, and that purpose must be identified in light of the context of the statute, its objective and the legislative intent: this is the teleological approach;- The teleological approach will favour the taxpayer or the tax department depending solely on the legislative provision in question, and not on the existence of predetermined presumptions;- Substance should be given precedence over form to the extent that this is consistent with the wording and objective of the statute;- Only a reasonable doubt, not resolved by the ordinary rules of interpretation, will be settled by recourse to the residual presumption in favour of the taxpayer. [43]            In the course of his Reasons, Gonthier J., at pages 15 and 16, identified the two purposes of tax legislation in Canada, namely, the raising of funds by the government to cover its expenditures and for the attainment of social and economic purposes. [44]            Turning to subsection 56(1) of the Act, it appears to me that the purpose of the provision is more in line with the traditional purpose of taxing legislation, i.e. to raise funds to cover government expenditures: the stated purpose of the subsection is to include in a taxpayer's income specified sources of income, save those which have been expressly exempted by the provision. ...

  [75]          The February 1993 Technical Notes issued by the Department of Finance describe the policy rationale which informs subsection 181(5) of the ETA:  ...   ...

Peter Thompson   [38]     Peter Thompson was the Assistant Housemaster in the Powell House from September 1993 to summer 1996. ...

  [21] (1993), [1994] 1 C.T.C. 368 (F.C.T.D.), rev’d on other grounds (1994), [1996] 3 C.T.C. 74 (F.C.A ...

It was noted that the trust agreement between AIL and RBC Trust Company of May 13, 1993, had certain built-in protections required by OSFI, including the Superintendent's approval for vesting an asset in trust, or withdrawing an asset vested in trust, subject to exceptions on certain assets. ...

In a 1993 Technical Interpretation [14] the CRA first addresses the need to determine whether a particular US state’s LLCs should be considered corporations or partnerships based upon their particular characteristics. [15] The CRA went on to say that, if an LLC is treated as a partnership for purposes of the US Code such that the partners rather than the company are liable to tax on the company’s income, the LLC will not be considered a resident of the US for purposes of the US Treaty. ...

He referred the assessments back to the Minister for reconsideration, on the assumption that the only advances included in the appellant’s capital under paragraph 181.2(3)(c) are the following:   1990 taxation year:            $73,781,000; 1991 taxation year:            $66,463,000; 1992 taxation year:          $207,820,000; 1993 taxation year:          $224,301,347; 1994 taxation year:          $423,237,117; 1995 taxation year:          $477,658,576; 1996 taxation year:          $250,700,000; 1997 taxation year:          $249,400,000; 1998 taxation year:          $332,100,000; 1999 taxation year:       $1,246,100,000; 2000 taxation year:       $1,482,400,000; and 2001 taxation year:       $1,304,100,000 ...