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FCA
Urichuk v. The Queen, 93 DTC 5120, [1993] 1 CTC 226 (FCA)
The Queen, 93 DTC 5120, [1993] 1 CTC 226 (FCA) Hugessen, J.A.:— We are all of the view that the learned trial judge committed no error when he looked at all the circumstances surrounding the making of the agreement between the appellant and his wife in order to determine that the payment of $45,000 and the three further payments of $50,000 each, spread over a little more than two years, were lump sum payments and not “allowance... for the maintenance" of the wife. ...
FCA
MNR v. Devor, 93 DTC 5098, [1993] 1 CTC 142 (FCA)
Devor, 93 DTC 5098, [1993] 1 CTC 142 (FCA) Mahoney, J.A.:—In refusing to strike out the statement of claim, the learned trial judge relied on the decision of one of his colleagues in Optical Recording Corp. v. ...
FCA
Grace M. Carlile v. Her Majesty the Queen, [1993] 2 CTC 345
Her Majesty the Queen, [1993] 2 CTC 345 Mahoney, J.A.:— This file has been referred to me for directions. ... The trial judge rendered his decision orally from the bench on February 24, 1993. ...
FCA
Gilbert v. The Queen, 93 DTC 5124, [1993] 1 CTC 233 (FCA)
The Queen, 93 DTC 5124, [1993] 1 CTC 233 (FCA) Décary, J.A.:— In February 1987, the applicant paid $6,500 into his wife’s registered retirement savings plan (RRSP). ...
FCA
Lan v. Macdonald v. Her Majesty the Queen, [1993] 2 CTC 75, 93 DTC 5318
Her Majesty the Queen, [1993] 2 CTC 75, 93 DTC 5318 Mahoney, J.A.:—This application for judicial review seeks to set aside a decision of the Tax Court which, on the respondent's motion, quashed the applicant's appeal against his 1988 income tax assessment on finding that the notice of appeal disclosed no arguable ground of appeal. ...
FCA
Canadian Union of Public Employees v. Minister of National Revenue, [1993] 1 CTC 185, 93 DTC 5099
Minister of National Revenue, [1993] 1 CTC 185, 93 DTC 5099 Pratte, J.A.:— We are all of the view that this motion to quash must succeed. ...
FCA
The Queen v. Timpson, 93 DTC 5281, [1993] 2 CTC 55 (FCA)
Timpson, 93 DTC 5281, [1993] 2 CTC 55 (FCA) MacGuigan, J.A. (orally):—The leading case with respect to the deduction of farming losses from income from another source is Moldowan v. ...
FCA
The Queen v. Carew, 92 DTC 6608, [1993] 1 CTC 1 (FCA)
Carew, 92 DTC 6608, [1993] 1 CTC 1 (FCA) Hugessen, J.A.:—This is an appeal from an order of the Tax Court of Canada dismissing the appellants application to extend the time for filing the reply to the notice of appeal. ...
FCA
Société de Projets ETPA Inc. v. MNR, 93 DTC 516, [1993] 1 CTC 46 (TCC)
MNR, 93 DTC 516, [1993] 1 CTC 46 (TCC) Marceau, J.A.:—This is an appeal from a decision of the Minister of National Revenue rejecting the application by the Canada UNI Association to be granted the status of "charity" under paragraph 149.1(1)(b) of the Income Tax Act, R.S.C. 1952, c. 148 (am. ...
FCA
Francois Fiore and Gino Fiore v. Her Majesty the Queen, [1993] 2 CTC 68
Her Majesty the Queen, [1993] 2 CTC 68 Létourneau, J.A.:—The Court has before it two applications for judicial review made pursuant to sections 28 and 18.1 of the Federal Court Act [1] and brought against a Tax Court of Canada decision rendered orally in May 1992. ...