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FCA
The Queen v. Silden, 93 DTC 5362, [1993] 2 CTC 123 (FCA)
Silden, 93 DTC 5362, [1993] 2 CTC 123 (FCA) Pratte, J.A.:—This is an appeal from a judgment of the Trial Division allowing an appeal from a decision of the Tax Court of Canada dismissing the respondent's appeal from his 1981 income tax assessment. ...
FCA
Miller v. The Queen, 93 DTC 5035, [1993] 1 CTC 269 (FCA)
The Queen, 93 DTC 5035, [1993] 1 CTC 269 (FCA) Mahoney, J.A.:— This is an appeal from a reported decision of the Trial Division ([1990] 2 C.T.C. 4, 90 D.T.C. 6335) arising out of a mistake made by the respondent in preparing his 1982 income tax return. ...
FCA
Sidhu v. MNR, 93 DTC 5453, [1993] 2 CTC 278 (FCA)
MNR, 93 DTC 5453, [1993] 2 CTC 278 (FCA) Mahoney, J.A. (Robertson and McDonald, JJ.A., concurring):—This section 28 application seeks to set aside a decision of the Tax Court of Canada on an appeal from an income tax assessment conducted under its informal procedures. ...
FCA
Marcel Piché v. Minister of National Revenue, [1993] 2 CTC 166, 93 DTC 5283
Minister of National Revenue, [1993] 2 CTC 166, 93 DTC 5283 Létourneau, J.A. ...
FCA
National Importers Ltd. And Grantham Foods Ltd. v. Her Majesty the Queen, [1993] 1 CTC 227
Her Majesty the Queen, [1993] 1 CTC 227 Robertson, J.A.:—These two appeals arise from a decision of a learned trial judge wherein he dismissed the appellants' appeals with respect to certain notices of assessment issued by the Minister of National Revenue. ...
FCA
Canadian Turbo (1993) Ltd. v. R., [1997] 1 CTC 130
Canadian Turbo (1993) Ltd. v. R., [1997] 1 CTC 130 McDonald J.A.: — This is an appeal from a judgment of the Trial Division, pronounced on May 18, 1995, which set aside a determination by the Minister of National Revenue that excise tax paid by the respondent, Canadian Turbo, on the sale of gasoline and diesel fuel was not refundable. ... (now Canadian Turbo (1993) Ltd.), sold gasoline and diesel fuel and paid and remitted tax on the sale pursuant to Part VI of the Excise Tax Act. ...
FCA
Schachtschneider v. The Queen, 93 DTC 5298, [1993] 2 CTC 178 (FCA)
The Queen, 93 DTC 5298, [1993] 2 CTC 178 (FCA) Mahoney, J.A.:—This is an application for judicial review of an unreported decision of the Tax Court of Canada, ensuing upon an informal hearing (file no. 91-1006, King, D.J., November 6, 1991). ... Effective for the 1993 tax year, the definitions of spouse and marriage in section 252 of the Act have been amended to include common law spouses. ... Rev. 925; Edward McCaffery, Taxation and the Family: A Fresh Look at Behavioral Gender Biases in the Code, (1993), 40 U.C.L.A. ...
FCA
The Queen v. Vancouver Art Metal Works Ltd., 93 DTC 5116, [1993] 1 CTC 346 (FCA)
., 93 DTC 5116, [1993] 1 CTC 346 (FCA) Létourneau, J.A. (Marceau, Robertson, JJ.A concurring):— Pursuant to Rule 474 of the Federal Court Rules, the parties had submitted the following question of law for a determination: Do the words" a trader or dealer in securities" in subsection 39(5) or the Income Tax Act, R.S.C. 1952, c. 148 (am. ...
FCA
The Queen v. Shaw, 93 DTC 5121, [1993] 1 CTC 221 (F.C.A.)
Shaw, 93 DTC 5121, [1993] 1 CTC 221 (F.C.A.) Linden, J.A.:—The issue on this appeal is whether a payment of money described as “interest” on a delayed settlement payment representing compensation for expropriated land should be characterized as interest and taxed as income, according to paragraph 12(1)(c) of the Income Tax Act, R.S.C. 1952, c. 148 (am. ...
FCA
Stursberg v. The Queen, 93 DTC 5271, [1993] 2 CTC 76 (FCA)
The Queen, 93 DTC 5271, [1993] 2 CTC 76 (FCA) Hugessen J.A.:—This is an appeal from a decision of Reed, J. in the Trial Division dismissing an appeal from a decision of Mogan, T.C.C.J. in the Tax Court of Canada which, in turn, had dismissed the taxpayer's appeal from the Minister's assessment. ...