Search - 德国民法典第1993条

The Queen, 93 DTC 953, [1993] 2 CTC 2409 (TCC)-- summary under Subsection 165(3) Summary Under Tax Topics- Income Tax Act- Section 165- Subsection 165(3) Beaubier, J. followed the decision in Apfelbaum v. ...

The Queen, 93 DTC 953, [1993] 2 CTC 2409 (TCC)-- summary under Agency Summary Under Tax Topics- Income Tax Act- Section 9- Agency- Agency A wife was found not to have engaged in transactions (which were part of an arrangement for income splitting with her husband) as agent for her husband given that she was motivated by a desire for more income for herself and was a more enthusiastic participant in the transactions than her husband. ...

The Queen, 93 DTC 235, [1993] 1 CTC 2411 (TCC)-- summary under Paragraph (g) Summary Under Tax Topics- Income Tax Act- Section 66.1- Subsection 66.1(6)- Canadian exploration expense- Paragraph (g) An underground mining operation was a new mine rather than an expansion of the open pit mine which lay above it, given that it constituted a separate and a distinct extraction facility. ...

MNR, 93 DTC 358, [1993] 2 CTC 2136 (TCC)-- summary under Subsection 129(4.1) Summary Under Tax Topics- Income Tax Act- Section 129- Subsection 129(4.1) In upholding the contention of the taxpayer ("Mid-Western") that income from surplus cash invested in short-term deposits gave rise to Canadian investment income, Christie A.C.J. accepted evidence that "a financial relationship of dependence did not exist between the funds to generate the interest in dispute and the active business carried on by Mid-Western". ...

The Queen, 93 DTC 295, [1993] 1 CTC 2435 (TCC)-- summary under Cost of Labour Summary Under Tax Topics- Income Tax Regulations- Regulation 5202- Cost of Labour The taxpayer, which used employees throughout the year to manufacture and erect modular buildings, was able to treat amounts paid to subcontractors for the same work during the months of May to August of each year, when it tripled its production in order to manufacture portable school rooms, as the cost of labour. ...

The Queen, 93 DTC 552, [1993] 2 CTC 2330 (TCC)-- summary under Subsection 160(1) Summary Under Tax Topics- Income Tax Act- Section 160- Subsection 160(1) It was found that the taxpayer had a 50% interest in property transferred to her by her husband on the basis of there being either a resulting trust or constructive trust in relation to such property. ...

The Queen, 95 DTC 311, [1993] 2 CTC 3125 (TCC)-- summary under Subsection 80(1) Summary Under Tax Topics- Income Tax Act- Section 80- Subsection 80(1) promissory note enforceable A promissory note that the taxpayer had given as consideration for a limited partnership interest acquired by him was found to be a legally enforceable claim of the banks to which it had been assigned. ...

MNR, 94 DTC 1603, [1993] 2 CTC 3009 (TCC)-- summary under Start-Up and Liquidation Costs Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Start-Up and Liquidation Costs Expenses claimed by the taxpayer as soft costs in respect of condominium investments were found to have been incurred prior to the date of acquisition of the condominiums (notwithstanding that they were paid as "adjustments" at the time of closing), with the result that they were non-deductible to the taxpayers. ...

The Queen, 93 DTC 995, [1993] 2 CTC 2247 (TCC), aff'd 96 DTC 6544 (FCA)-- summary under Income-Producing Purpose Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Income-Producing Purpose A debt to the taxpayer from a non-resident corporation, which arose because of the taxpayer's inadvertent failure to withhold from interest payments made to the non-resident and which the taxpayer was unable to collect, was not deductible and did not relate to a deductible expenditure. ...

MNR, 93 DTC 451, [1993] 1 CTC 2710 (TCC)-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development A supposed research project which folded after the initial phases of work and therefore consisted only of routine data collection and research in the educational area did not qualify as scientific research described in Regulation 2900. ...