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FCA
Canada v. VIH Logging Ltd., 2005 DTC 5095, 2005 FCA 36
According to expert valuation evidence presented at trial, which the Judge accepted, the fair market value of the share of Old VIH on February 23, 1993 was $1,443,000. [5] Three transactions occurred on February 23, 1993. ... The fair market value of the share of Old VIH would have been reduced as follows with the payment of each of the cash dividends: Fair market value as of February 23, 1993 Dividend paid on February 24, 1993 Dividend paid on February 25, 1993 Fair market value prior to the stock dividend $1,443,000 980,629 $ 462,371 416,800 $ 45,571 [9] On February 27, 1993, Old VIH purchased seismic data for $2,200,000. ... However, the same could not be said of the stock dividend, because, by February 25, 1993 when the stock dividend was paid, the income earned by Old VIH up to February 23, 1993 was almost entirely depleted by the cash dividends. [28] The Crown argues that the Judge was not correct to include in the safe income of Old VIH any of the earnings of Old VIH for the period from March 1, 1992 to February 23, 1993 (I will refer to this as the "stub period" because it represents an incomplete part of the 1993 fiscal year of Old VIH which ended on February 28, 1993). ...
FCA
Ruth and John Giagnocavo v. Her Majesty the Queen, the Attorney General of Canada, Revenue Canada and All and Any Judges and Court Personnel of the Provincial Court at Stratford, Ontario or Any Agents Thereof, [1995] 2 CTC 2, 95 DTC 5411
:-On May 31, 1993 the plaintiffs commenced this action. On application of the first-named respondents (hereafter referred to as "the Crown") the associate senior prothonotary on July 19, 1993 struck out the statement of claim as disclosing no cause of action. Rothstein J. dismissed an appeal from this decision on August 31, 1993. The plaintiffs then filed an appeal from the decision of Rothstein J. on September 13, 1993, becoming appellants in the present proceeding in this Court. ...
FCA
Rooke v. Canada (Attorney General), 2002 DTC 6442, 2002 FCA 393 (FCA)
Rooke's absences from Canada for 1993, 1994 and 1995 are not in dispute, and are summarized in the following table: Period Days in Canada Days outside Canada Location Contractor 1993 Jan 01 1993 Jan 09 9 1993 Jan 10 1993 Jan 28 19 U.S.A. Monsanto 1993 Jan 29 1993 Feb 17 20 1993 Feb 18 1993 June 06 109 U.S.A. Monsanto 1993 June 07 1993 July 10 34 1993 July 11 1993 July 29 19 Taiwan Monsanto 1993 July 30 1993 Oct 11 74 1993 Oct 12 1993 Nov 15 35 Taiwan Monsanto 1993 Nov 16 1994 Mar 18 123 1994 Mar 19 1994 Apr 16 29 U.S.A. ...
FCA
SMX Shopping Centre Ltd. v. Canada, 2003 FCA 479
The disallowance of the 1994 management fee and the Golbanoo joint venture loss resulted in the reduction of the 1994 non-capital loss and a corresponding reduction, in 1993, of the 1994 non-capital loss carry-back. [8] The reassessments increased the tax liability of SMX for 1993. ... As there was no tax payable for 1994, only the 1993 reassessment was properly before the Tax Court. ... For the 1993 taxation year of SMX, the extended reassessment period expired on August 9, 2001. ...
FCA
Kowdrysh v. The Queen, 2001 DTC 5221, 2001 FCA 34
Revenue Canada refused the tax credit to the appellant on the basis that property in the air seeder had not passed to the appellant in 1993. ... He traded in his old one for $22,615 and made a first payment of $2,500 post-dated to December 4, 1993. ... If there could have been a doubt that the equipment bought by the appellant was ascertained on November 30, 1993, and I have concluded that there was none, this doubt would have, in any event, been dissipated by December 31, 1993 before the program expired. ...
FCA
Bakorp Management Ltd. v. Canada (National Revenue), 2016 FCA 74
Bakorp filed its tax returns for 1993 and 1995 and reported a Part IV tax liability in each return. ... On February 3, 2000, the Minister applied the Overpayment to the outstanding Part IV tax liability for 1993. ... The date the Overpayment was applied to Bakorp’s liability for 1993 was February 3, 2000. ...
FCA
Brown v. Canada, 2003 DTC 5298, 2003 FCA 192 (FCA)
By agreement made as of October 1, 1993, the CEG Partnership agreed to acquire, on a date to be agreed upon, but not later than December 31, 1993, the software programs from ASC (the Software Agreement). ... The appellant acquired 80 units on December 31, 1993. [3] The CEG Partnership purchased the software programs from ASC for US$8,170,000 on December 31, 1993. ... The words "at a particular time" in this case refer to any time in 1993 including December 31, 1993, and any time in 1994, as these are the years when the appellant sought to deduct partnership losses. ...
FCA
Del Zotto v. Canada, [1996] 2 CTC 22, 96 DTC 6222
The Minister of National Revenue, [1993] 2 C.T.C. 342, 93 D.T.C. 5455, at page (C.T.C. 343) 5456). ... At the same time, the Case Management Judge ordered a partial lifting of the stay order of November 26, 1993. ... There was in particular no evidence that the facts had changed since the making of the stay order of November 26, 1993. ...
FCA
Miller v. Canada, 2002 FCA 81
One appeal was that of Ronald James Miller for 1992, 1993 and 1994. The other appeal was that of R. ... (the Corporation) for its taxation years ending February 28, 1992, 1993 and 1994. ... There is some evidence of third party sales of the enhanced software after 1993. ...
FCA
Godsell v. The Queen, 2001 DTC 5384, 2001 FCA 196
The appellant filed a Notice of Objection on May 12, 1992 and a Notice of Appeal on May 27, 1993. The Minister further reassessed on July 15, 1993. Section 152(4) of the Income Tax Act provides for a reassessment period of three years. ... The time period from the Notice of Objection on May 12, 1992 to July 15, 1993 was approximately 14 months. ...