Search - 德国民法典第1993条

MNR, 93 DTC 1058, [1993] 2 CTC 2793 (TCC)-- summary under Paragraph 12(1)(c) Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(1)- Paragraph 12(1)(c) sale one day prior to maturity The taxpayer purchased significant quantities of treasury bills through its broker and sold them one day prior to maturity. ...

MNR, 93 DTC 250, [1993] 1 CTC 2279 (TCC)-- summary under Proceeds of Disposition Summary Under Tax Topics- Income Tax Act- Section 13- Subsection 13(21)- Proceeds of Disposition After a customer had negotiated the purchase price with a supplier, the taxpayer would purchase equipment from the supplier and enter into a net lease with the customer that typically had a term of 36 months and (under a collateral arrangement that generally was not written into the lease terms) gave the customer the right to acquire the equipment at 10% of its actual cost on expiry of the lease. ...

MNR, 93 DTC 148, [1993] 1 CTC 2021 (TCC)-- summary under Subsection 15(2.6) Summary Under Tax Topics- Income Tax Act- Section 15- Subsection 15(2.6) no indefinite tax deferral After noting (at para. 33) that "the object of 15(2)(b) is to prevent the use of a shareholder loan account for indefinite tax deferral purposes through loans, advances and other transactions followed by repayments involving reborrowings... ...

The Queen, 95 DTC 277, [1993] 2 CTC 3203-- summary under Paragraph 6(1)(a) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a) In finding that the taxpayer received a benefit when a second mortgage on his Alberta home owing by him to his employer was settled for less than the amount owing by him, Sarchuk TCJ. found that section 41 of the Property Act (Alberta) merely restricted the ability of the mortgagee to collect an amount, but did not affect the quantum of liability of the taxpayer. ...

MNR, 93 DTC 291, [1993] 1 CTC 2429 (TCC)-- summary under Paragraph 6(1)(a) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a) The taxpayer, who was the employee of a company that assembled and sold tour packages, was found to have received a taxable benefit equal to the average cost to the company of airline seats which it chartered when the company provided to the taxpayer, along with other employees, the right to use seats which the company had been unable to sell to customers. ...

MNR, 93 DTC 680, [1993] 1 CTC 2176 (TCC)-- summary under Paragraph 20(1)(c) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c) The taxpayer was given the opportunity to purchase 10.25% of the shares of a private company ("Choisy") for which he worked. ...

MNR, 93 DTC 999, [1993] 2 CTC 2244 (TCC)-- summary under Subsection 152(2) Summary Under Tax Topics- Income Tax Act- Section 152- Subsection 152(2) Notices of reassessment that were sent by registered mail by the Minister were returned by the post office, with the envelopes marked "unclaimed". ...

MNR, 93 DTC 999, [1993] 2 CTC 2244 (TCC)-- summary under Subsection 244(14) Summary Under Tax Topics- Income Tax Act- Section 244- Subsection 244(14) Notices of reassessment that were sent by registered mail by the Minister were returned by the post office, with the envelopes marked "unclaimed". ...

MNR, 93 DTC 1473, [1993] 2 CTC 3148 (TCC)-- summary under Resolving Ambiguity Summary Under Tax Topics- Statutory Interpretation- Resolving Ambiguity In rejecting a submission that there was an ambiguity in Regulation 2902 that should be resolved in the taxpayer's favour, Kempo, TCJ. stated (p. 1478): The ostensible anomaly is resolvable by the contemporary words-in-total-context approach which has as its focus the determination of the object and purpose of these provisions. ...

The Queen, 93 DTC 1043, [1993] 2 CTC 2681 (TCC)-- summary under Subsection 163(2) Summary Under Tax Topics- Income Tax Act- Section 163- Subsection 163(2) The taxpayer purchased a farm property for consideration comprising $166,824 plus his commitment to build a residence for the vendor with an agreed value of $76,649. ...