Search - 德国民法典第1993条

The Queen, 93 DTC 5313, [1993] 2 CTC 113 (FCA), rev'd supra.-- summary under Inventory Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Inventory In his concurring reasons for judgment, Marceau J.A. found that a single property held in connection with an adventure or concern in the nature of trade did not constitute "inventory". ...

Devor, 93 DTC 5098, [1993] 1 CTC 142 (FCA)-- summary under Section 29 Summary Under Tax Topics- Other Legislation/Constitution- Federal- Federal Courts Act- Section 29 A statement of claim seeking a declaration that waivers "extracted" from the taxpayer were void and a writ of certiorari quashing the reassessments based thereon, was struck out on the basis that the relief claimed was beyond the jurisdiction of the Court. ...

The Queen, 93 DTC 5351, [1993] 2 CTC 257 (FCA)-- summary under Subparagraph 40(2)(g)(ii) Summary Under Tax Topics- Income Tax Act- Section 40- Subsection 40(2)- Paragraph 40(2)(g)- Subparagraph 40(2)(g)(ii) No deduction was available under s. 50(1)(a) in respect of a loan made by a corporation to an affiliate in the absence of any evidence that the recipient of the loan would be able to repay it. ...

The Queen, 93 DTC 5035, [1993] 1 CTC 269 (FCA)-- summary under Subsection 110.4(1) Summary Under Tax Topics- Income Tax Act- 101-110- Section 110.4- Subsection 110.4(1) There was no statutory authority to allow an amendment of the taxpayer's original election which he now considered to be desirable as a result of the Crown's disallowance of most of his claim for an RRSP deduction for the year in question. ...

., 93 DTC 5199, [1993] 1 CTC 363 (FCA)-- summary under Context Summary Under Tax Topics- Statutory Interpretation- Context MacGuigan J.A. applied the "words-in-total-context approach" in finding that because Puerto Rico was a country for purposes of Regulations 5907(10)(b) and (c), it also should be considered to be a country for purposes of Regulation 5907(10)(a). ...

MNR, 93 DTC 5453, [1993] 2 CTC 278 (FCA)-- summary under Evidence Summary Under Tax Topics- General Concepts- Evidence The trial judge had committed an error of law when he concluded that failure of the taxpayers to keep proper records of wages paid by them to employees was fatal to their claim for a corresponding deduction from income. ...

., 93 DTC 5116, [1993] 1 CTC 346 (FCA)-- summary under Noscitur a Sociis Summary Under Tax Topics- Statutory Interpretation- Noscitur a Sociis Létourneau J.A. noted (at p. 5118) that an order for the noscitur a sociis rule to apply "there must be a distinct genus or category from which the general words can take their colour or meaning", and there is no such genus in s. 39(5) of the Act which would justify restricting the phrase "trader or dealer in securities" to registered dealers. ...

Devor, 93 DTC 5098, [1993] 1 CTC 142 (FCA)-- summary under Section 18 Summary Under Tax Topics- Other Legislation/Constitution- Federal- Federal Courts Act- Section 18 The Federal Court had no jurisdiction to declare that waivers, which allegedly had been extracted from the taxpayer under compulsion and duress, were void. ...

The Queen, 93 DTC 5298, [1993] 2 CTC 178 (FCA)-- summary under Subsection 15(1) Summary Under Tax Topics- Other Legislation/Constitution- Charter (Constitution Act, 1982)- Subsection 15(1) The fact that s. 118(1) at the time provided a greater benefit to an unmarried couple with a child than to a married couple with a child could not be characterized as discrimination based on religion contrary to s. 15 of the Charter; nor did it interfere with either's religious belief or practice contrary to s. 2(a) of the Charter. ...

The Queen, 93 DTC 5298, [1993] 2 CTC 178 (FCA)-- summary under Paragraph 2(a) Summary Under Tax Topics- Other Legislation/Constitution- Charter (Constitution Act, 1982)- Paragraph 2(a) The fact that s. 118(1) at the time provided a greater benefit to an unmarried couple with a child than to a married couple with a child could not be characterized as discrimination based on religion contrary to s. 15 of the Charter; nor did it interfere with either's religious belief or practice contrary to s. 2(a) of the Charter. ...