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TCC (summary)
Placements Marcel Lapointe Inc. v. MNR, 93 DTC 821, [1993] 1 CTC 2506, [1993] 1 CTC 2261, [1993] DTC 809 (TCC) -- summary under Personal Services Business
MNR, 93 DTC 821, [1993] 1 CTC 2506, [1993] 1 CTC 2261, [1993] DTC 809 (TCC)-- summary under Personal Services Business Summary Under Tax Topics- Income Tax Act- Section 125- Subsection 125(7)- Personal Services Business A business of providing construction cost appraisal services, which the taxpayer provided to a corporation through the services of its president and principal shareholder, represented a personal services business, given that such individual might reasonably be regarded as an employee of the recipient of the services. ...
TCC (summary)
Stevens v. MNR, 93 DTC 291, [1993] 1 CTC 2429 (TCC) -- summary under Interpretation Bulletins, etc.
MNR, 93 DTC 291, [1993] 1 CTC 2429 (TCC)-- summary under Interpretation Bulletins, etc. ...
TCC (summary)
598606 Ontario Ltd. v. The Queen, 93 DTC 142, [1993] 1 CTC 2001 (TCC) -- summary under Subsection 192(4)
The Queen, 93 DTC 142, [1993] 1 CTC 2001 (TCC)-- summary under Subsection 192(4) Summary Under Tax Topics- Income Tax Act- Section 192- Subsection 192(4) The failure of the issuer to file a Form T-2110 destroyed the taxpayer's entitlement to the share purchase tax credit in respect of the shares. ...
TCC (summary)
Démolition A.M. de l'est du Québec Inc. v. MNR, 93 DTC 889, [1993] 2 CTC 2447 (TCC) -- summary under Paragraph (c)
MNR, 93 DTC 889, [1993] 2 CTC 2447 (TCC)-- summary under Paragraph (c) Summary Under Tax Topics- Income Tax Act- Section 125.1- Subsection 125.1(3)- Manufacturing or Processing- Paragraph (c) Garon J. rejected the Crown's submission that the activities of the taxpayer in demolishing buildings and other works constituted "construction". ...
TCC (summary)
LeBlanc v. MNR, 93 DTC 1564, [1993] 2 CTC 3054 (TCC) -- summary under Farming
MNR, 93 DTC 1564, [1993] 2 CTC 3054 (TCC)-- summary under Farming Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Farming Activities carried out in a vineyard consisting of the preparation of the soil, the planting of the vines, the growing of the grapes, and their ultimate harvesting, were "farming". ...
TCC (summary)
Gaitens v. The Queen, 93 DTC 54, [1993] 1 CTC 2168 (TCC) -- summary under Paragraph 227.1(2)(a)
The Queen, 93 DTC 54, [1993] 1 CTC 2168 (TCC)-- summary under Paragraph 227.1(2)(a) Summary Under Tax Topics- Income Tax Act- Section 227.1- Subsection 227.1(2)- Paragraph 227.1(2)(a) The Minister did not fulfil the precondition in s. 227.1(2)(a) when he filed a certificate that did not take into account the amount of a Part VIII refund that had been determined and assessed by the Minister on the same day. ...
TCC (summary)
International Petrodata Inc. v. The Queen, 93 DTC 110, [1993] 1 CTC 2189 (TCC) -- summary under Canadian Manufacturing and Processing Profits
The Queen, 93 DTC 110, [1993] 1 CTC 2189 (TCC)-- summary under Canadian Manufacturing and Processing Profits Summary Under Tax Topics- Income Tax Act- Section 125.1- Subsection 125.1(3)- Canadian Manufacturing and Processing Profits The sale and leasing of tapes and microfiches containing technical data on Canadian oil wells which the taxpayer had gathered, edited and organized was eligible for the deduction. ...
TCC (summary)
Low v. The Queen, 93 DTC 927, [1993] 2 CTC 2227 (TCC) -- summary under Principal Residence
The Queen, 93 DTC 927, [1993] 2 CTC 2227 (TCC)-- summary under Principal Residence Summary Under Tax Topics- Income Tax Act- Section 54- Principal Residence The taxpayer failed to establish that the ownership of a Florida condominium was held by a Liechtenstein "establishment" as bare trustee for the taxpayer. ...
TCC (summary)
Gestion Guy Ménard Inc. v. MNR, 93 DTC 1058, [1993] 2 CTC 2793 (TCC) -- summary under Specific v. General Provisions
MNR, 93 DTC 1058, [1993] 2 CTC 2793 (TCC)-- summary under Specific v. ...
TCC (summary)
Ritson Estate v. MNR, 93 DTC 1078, [1993] 2 CTC 2750 (TCC) -- summary under Shares
MNR, 93 DTC 1078, [1993] 2 CTC 2750 (TCC)-- summary under Shares Summary Under Tax Topics- General Concepts- Fair Market Value- Shares The executors were unsuccessful in establishing that the fair market value of shares of the deceased should be discounted for the requirement under British Columbia securities law that the shares be held pursuant to an escrow agreement given that, in fact, none of the shares issued to the deceased were ever deposited in escrow. ...