Search - 德国民法典第1993条

The Queen, 93 DTC 5313, [1993] 2 CTC 113 (FCA), rev'd supra. Létourneau, J.A. ...

Boger Estate, 93 DTC 5276, [1993] 2 CTC 81 (FCA) Heald, J.A.:—This is an appeal from a judgment of the Trial Division allowing the respondent's appeal with respect to a reassessment by the Minister of National Revenue ("the Minister”) dated January 12, 1984 in respect of the 1979 terminal tax return of Alexander Boger ("the taxpayer"). ...

The Queen, 93 DTC 5351, [1993] 2 CTC 257 (FCA) Mahoney, J.A. (Stone and McDonald, JJ.A. concurring):— This is an appeal from a reported decision of the Trial Division arising out of the assessment of the appellant's 1980 income tax return ([1986] 1 C.T.C. 418, 86 D.T.C. 6196). ...

., 93 DTC 5199, [1993] 1 CTC 363 (FCA) MacGuigan, J.A.:—The only issue on this appeal is whether a tax exemption granted by Puerto Rico to an affiliate of a Canadian corporation is an export incentive under Canadian income tax law. ...

The Queen, 93 DTC 5205, [1993] 2 CTC 34 (FCA) Robertson, J.A.:—The appellant maintains that he is entitled to a tax-free capital gain on the sale of his home and surrounding lands encompassing 8.99 acres. ...

Her Majesty the Queen, [1993] 2 CTC 9, 93 DTC 5186 Issac, C.J.:—This is an appeal from the order of a motions judge in the Trial Division which dismissed an appeal by the appellant, and allowed a crossappeal by the respondent, from an order of the associate senior prothonotary. ...

., [1993] 1 CTC 186, 93 DTC 5080 Isaac, C.J.:—This is an appeal from the order of a motions judge in the Trial Division dated November 8, 1991, allowing an appeal by the respondent made pursuant to Rule 336(5) of the Federal Court Rules from an order of the associate senior prothonotary. ...

Armstrong that the new 1993 loss would result in a non-capital loss for 1993, he requested that the loss be carried back to 1991. ... Armstrong's amended 1993 return represents two requests, one for a 1993 reassessment to recognize the new loss, and the other for a 1991 reassessment to apply the resulting 1993 non-capital loss to that year. ... Armstrong should have raised the issue of the 1993 rental losses before the conclusion of his Tax Court appeals for 1991 and 1993. ...

Taxation Year Adjustments to Deemed Dividend March 10, 1995 $ (25,332,237) March 10, 1994 (8,154,757) March 10, 1993 154,224,784   $ 120,737,790   [8]                For two of the three years listed in this notice of objection, the amount of the dividend was decreased and for the other year (1993) the amount of the dividend was increased (by substantially more than the amount of the reductions for 1994 and 1995). ... The Deemed Dividend, including the 1995 Receipt, was payable to the Appellant in the 1993 Year and, therefore, should be included in the Appellant's taxable income for the 1993 Year.   16.          ...   [39]            Simply listing subsection 84(3) of the Act as a relevant provision in the notice of appeal and stating that the $28,000,000 (which is the amount that the Minister had determined was subject to Part IV tax in 1995) was payable in 1993 and therefore should have been included in Bakorp’s taxable income in 1993, does not identify the legal argument based on the provisions of subsection 84(3) of the Act related to when the Deemed Dividend is received for the purposes of the Act ...

O/A VWV ENTERPRISES      1678700 CANADA INC. 0/A SACHA LONDON      ALDO SHOES (1993) INC., TRANSIT      (A DIVISIONOF ALDO SHOES)      AND GLOBO (A DIVISION OF ALDO SHOES)           Appellants     - and-      THE DEPUTY MINISTER OF NATIONAL REVENUE      Respondent      REASONS FOR JUDGMENT OF THE COURT      (Delivered from the Bench at Ottawa, Ontario,      on Thursday, November 25, 1999) STONE J.A. [1]      The Court is faced with determining two issues in this appeal on a "question of law" from a decision of the Canadian International Trade Tribunal under section 62 of the Special Import Measures Act 1 (the "Act"). ... O/A VWV ENTERPRISES      1678700 CANADA INC. 0/A SACHA LONDON      ALDO SHOES (1993) INC., TRANSIT      (A DIVISIONOF ALDO SHOES)      AND GLOBO (A DIVISION OF ALDO SHOES)           Appellants     - and-      THE DEPUTY MINISTER OF NATIONAL REVENUE      Respondent Heard at Ottawa, Ontario, on Thursday, November 25, 1999. ...