Search - 德国民法典第1993条

The Judge pointed out that the Government of Canada and the LCBO had entered into such an Agreement on January 19, 1993, and he reproduced the relevant provisions of the Agreement. ...   [37]            As explained above, the legal basis on which the CBSA purported to act when it collected the mark-up is the 1993 LCBO Agreement. ... The Judge was also in doubt as to whether the CBSA Act was sufficient to authorize the CBSA to give effect, in 2007, to the Agreement signed on January 19, 1993. ...

Kumar filed a notice of appeal in the Tax Court challenging income tax assessments for 1992, 1993 and 1994. ... Among the adjustments set out in the order are these: his business loss for 1992 was increased by $5,600, his business income for 1993 was reduced to zero from $6,054, and his business loss for 1994 was increased by $4,900. ... Kumar subsequently attempted to obtain the agreement of Revenue Canada to the changes he considered were required to his purchases for 1992, 1993 and 1994, but those efforts did not succeed. [9]                On May 25, 2004, Mr. ...

After Donohue had first assigned its investment in DMI to DSF and this investment had been written off its books, the restructuring proceeded as follows: (i)          On November 12, 1993, a new company, Donohue Matane (1993) Inc. (DMI 1993) was formed, in which DMI subscribed for one common share. The articles of DMI 1993 allowed the issuance of shares having characteristics similar to those of the capital stock of DMI; (ii)         On November 15, 1993, DMI transferred to DMI 1993 almost all its assets and liabilities, i.e. essentially the Matane pulp mill, the two shore sawmills and the wood preparation centre, worth a total of $165,124,833, and liabilities in an equivalent amount. ... That same day, DSF and Rexfor, each holding 50% of DMI's shares, also became 50% shareholders each in DMI 1993, and the holders of DMI's preferred shares (Rexfor and the SDI) became the preferred shareholders of DMI 1993; (iv)        On December 22, 1993, DMI's common shares were sold to Cèdrico Inc. ...

To avoid the elimination of the PUC of the VHHC Holdings shares, in early 1993, Copthorne I transferred its shares in VHHC Holdings to Big City, its parent corporation, for their nominal fair market value (the “1993 Share Sale”) ... Did the Tax Court Judge err in concluding that the 1993 Share Sale was an avoidance transaction?   ... The Tax Court Judge found that the 1993 Share Sale was an avoidance transaction. ...

The first related to a claim by the appellant of a business loss for the 1993 tax year in the amount of $27,034. ... He sought to deduct the amount paid by him as an allowable business investment loss for the year 1993, that being the year when the payment was made by him. ...

This debt resulted from source deductions not submitted by the debtor for the period from October to December 1992 and January to November 1993.                           The objector argued that the seized property belonged to it since it had purchased the property by a notarized agreement made on November 18, 1993.  ... Finally, the Court notes a significant contradiction as to the nature of the contract of sale of November 18, 1993 between the statements it contained and those made by the witness Alain Joly in his examination.  ...

On July 23, 1993, it was decided that the 1991 and 1992 employment was not insurable. ... On December 16, 1993, they were advised that it had been decided that their employment was not insurable as no valid contract of service existed under an employer/employee relationship, that they were not employed at arm's length, and that it was not reasonable to assume that they would have entered into a substantially similar arrangement had they not been related to their employer. [4]                It was the December 16, 1993 decision that the applicants unsuccessfully appealed to the Tax Court. [5]                The applicants first say that there was no jurisdiction in the Minister, once having decided they were employed in insurable employment, subsequently making a decision they were not. ... While the Minister, in the decision of December 16, 1993, does not provide extensive reasons, the clear inference is that he obtained information which he did not originally have that caused him to conclude that the applicants were not engaged in insurable employment. [7]                A second argument made by the applicants is that the Minister has an obligation to call evidence in support of his assumptions in his reply to a notice of appeal. ...

The Judge's conclusion is summarized at paragraph 53 of his reasons: [53] Prior to December 1996, child support had been paid at the rate of $2,000 per month continuously from June 1993 and also from September 1991 to March 1993. ... Patricia ceased to be employed by Larry's law firm sometime from March 22 to May 31, 1993. ... Larry paid only $2,000 child support per month from June 1, 1993 to December 1996. ...

In a single set of reasons, the Judge dismissed their appeals from reassessments of income tax, for the year 1993 in the case of Mr. ... Since the benefit conferred on the partners by article 3.13 of the partnership agreement was, if applicable at all on the facts, both future and contingent, it was not captured as a "benefit" by the 1993 version of paragraph (2.4)(b). [10]            We do not agree. ... It may also be significant in this regard that, for its taxation years 1992 and 1993, Pruefer wrote off part of its billings to the partnership as bad or doubtful debts, yet continued to bill for services rendered. ...

The Applicant signed the transfer, had no lawyer acting for him and received no consideration or money. [4]         Unfortunately for the Applicant, on August 17, 1993, Revenue Canada had served upon him a Notice of Assessment in the amount of $43,000.00 in the following terms. ... " [5]                 Pursuant to subsection 165(1) of the Act, the respondent had until November 15, 1993 to serve on the Minister of National Revenue ("the Minister") his notice of objection to the notice of assessment. ... Hence, if a postal failure cannot save a taxpayer, he will not be saved by his failure to grasp the significance of a notice of assessment served on him. [14]            As there is no dispute that notice of assessment no. 7272 was sent by registered mail to the respondent on August 17, 1993, and that the respondent received it within a few days, his notice of objection was clearly served out of time. ...