Search - 德国民法典第1993条

M.N.R. [1993] C.I.T.T. 5. 4      These provisions read in part:      42. ... Antosko, [1994] 2 S.C.R. 312 at 326-27; Canadian Turbo (1993) Ltd. v. ...

(QL)), and the farm's projects remained the same for the 1993 and 1994 taxation years. [3]        For the 1993 and 1994 taxation years the appellant considered that all the farming expenses for his farm, $405,836 in 1993 and $258,402 in 1994, represented qualified scientific research and experimental development expenses ("SR & ED"). ... APPLICABLE LEGISLATION [9]        For the two taxation years 1993 and 1994 the Court must apply here the Act as it read in 1994. Some of the provisions we are concerned with are the same for both taxation years, 1993 and 1994. ...

For the 1993 tax year, you subscribed $2,500 to Émile Amireault on March 8, 1993, for paintings having a value of $24,600, according to the appraisal by Émile Amireault himself. ... He never claimed the paintings that were donated in 1993 and 1994 came from the Gingras estate. ... Moreover, the certificate of appraisal dated December 15, 1993, prepared by Mr. ...

No. 297 (Q.L.)) vacating the reassessments issued with respect to the Taxpayer's 1993 and 1994 taxation years on the basis that he was not in receipt of a deemed dividend pursuant to section 84.1 of the Income Tax Act (the Act). [2]                 The narrow issue raised by the appeal is whether the reference in section 84.1 of the Act to subsection 186(4) incorporates the definition of the word "control" as found in subsection 182(2). ... As noted in paragraphs 1.13 and 1.14 of the Statement of Agreed Facts, the Minister in issuing the reassessments considered that the actual amount of the deemed dividend was $419,890 and $173,304 for the 1993 and 1994 taxation years respectively which amounts were grossed up by 25% pursuant to paragraph 82(1)(b). [18]            In order to arrive at these amounts, the Minister computed the deemed dividend by reference to the fair market value of the Leader shares (the "subject shares") which has been agreed to be $673,310. ... However, what is to be reflected in D of the formula set out thereunder is not the fair market value of the subject shares but the fair market value of the non-share consideration received by the Taxpayer for the subject shares. [20]            The non-share consideration received in this instance are the notes, the fair market value of which has been agreed to be $318,268 and $104,998 for the 1993 and 1994 taxation years respectively (paragraph 1.10 of the Statement of Agreed Facts). ...

Audit of the appellant's 1993 fiscal year [32]            The appellant was again audited by the Minister for its 1993 fiscal year. ... This deficiency was also identified during our last audit for the fiscal period ending August 31, 1993 in our letter dated January 23, 1997. ... All of the above were explained to you in our letters dated October 22, 1986, October 19, 1987 and October 21, 1993. ...

Philips Electronics Ltd. (1993), 151 N.R. 178 (F.C.A.); Wilbur-Ellis Co. of Canada Ltd. v. ...

It will be useful to immediately reproduce the subsection: 163. (2) Every person who, knowingly, or under circumstances amounting to gross negligence, has made or has participated in, assented to or acquiesced in the making of, a false statement or omission in a return, form, certificate, statement, or answer (in this section referred to as a "return") filed or made in respect of a taxation year for the purposes of this Act, is liable to a penalty... 163. (2) Toute personne qui, sciemment ou dans des circonstances équivalent à faute lourde dans l'exercice d'une obligation prévue à la présente loi ou à son règlement, fait un faux énoncé ou une omission dans une déclaration, un formulaire, un certificat, un état ou une réponse- appelé « déclaration » au présent article- remplit, produit ou présente, selon le cas, pour une année d'imposition conformément à la présente loi ou à son règlement, ou y participe, y consent ou y acquiesce est passable d'une pénalité... [3]                The facts relevant to the appeals are straightforward and can be briefly summarized as follows. [4]                The appellants, senior employees of Pfizer Canada (except for Bertram Whitzman, who was an employee of Pfizer USA, and Guy Riendeau, who was an employee of Pfizer North America), received from their employers options to acquire shares of Pfizer USA (the stock options). [5]                During the course of taxation years 1993 to 1997, the appellants exercised their options and sold their shares in Pfizer U.S.A. The following table highlights the proceeds which resulted from the sale of the shares for each appellant and in respect of each specific tax year: 1993 1994 1995 1996 1997 TOTAL Klapka $16,577 $19,971 $36,548 Panini $9,083 $22,259 $148,572 $179,914 Riendeau $41,233 $41,233 Riordan $36,406 $86,877 $80,519 $858,955 $1,062,757 Southin $63,788 $184,689 $248,477 Whitzman $13,103 $22,244 $19,455 $120,563 $175,365 [6]                As the appellants did not report the benefits resulting from the exercise of their stock options in their income tax returns for the years at issue, the Minister issued reassessments against each one of them, imposing tax, interest and penalties. ... Pfizer Canada did not report the benefits related to the exercise of the Stock Options on the Appellant's T4 slips.... a total of 46 Pfizer Canada employees exercised Stock Options over the period 1993 to 1997. 23 individuals, including the Appellant, failed to report the benefits related to the exercise of their Stock Options. [13]            At paragraph 6 of his reasons, the Judge finds that after informing Pfizer USA of their decision to exercise their stock options, the appellants received a cheque from the brokerage firm of Merrill Lynch. ...

Limited [1931] S.C.R. 494. 7 Canadian Turbo (1993) Ltd. v. R. [1997] 1. ...

During the 1993 through 1998 tax years, the connecting factors and the weight to be accorded to them in respect to the situs of employment income was evolving and was not settled ... At paragraph 98, the Federal Court stated:     Third, during the applicants [sic] taxation years 1993 through 1998, the connecting factors appropriate and the weight to be accorded to them in respect to the situs of employment income was evolving and was not settled. ...

The support amount shall be reviewed for September 1, 1993, the date of the sale of the family residence; 17.       ... Dagenais. [5]                 The sale of the family residence did not take place on September 1, 1993. ... Moreover, the exercise of the right to request a review of the support was made subject to a suspensive condition: that right arose only at the time of the sale in question. [14]            Not only was the stated date of the sale (September 1, 1993) a secondary element of the agreement but in June 1993, that date could not be determined with certainty. ...