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FCTD
Rothmans, Benson & Hedges Inc. v. Minister of National Revenue, [1998] 2 C.T.C. 176
Canada (Minister of Employment & Immigration)</em>(1992), [1993] 1 F.C. 602 (Fed. ...
FCTD
Burnet v. Minister of National Revenue, [1997] 3 C.T.C. 192, 97 D.T.C. 5346
</p>] claiming only half of the loss on the basis that he was a joint owner of the property. 6 By letter dated January 23, 1993, the Respondent agreed to hold the Applicant's October 5, 1992 application in abeyance pending the decision of Mr. ...
FCTD
Borstad Welding Supplies (1972) Limited v. The Queen, 94 DTC 6205, [1994] 1 CTC 395 (FCTD)
:—On September 9, 1993, reasons for judgment in this matter were issued (Borstad Welding Supplies (1972) Ltd. v. Canada, [1993] 2 C.T.C. 266, 93 D.T.C. 5457). As was noted on the last page of those reasons, I had been asked b counsel at the end of the trial to defer judgment if I should find for the plaintiff. ...
FCTD
The Queen v. Twigg, 96 DTC 6297, [1996] 3 CTC 135 (FCTD)
Minister of National Revenue, [1993] 1 C.T.C. 2585, 93 D.T.C. 98 (T.C.C.); and Timpson v. Minister of National Revenue, [1993] 2 C.T.C. 55 (sub nom. R. v. Timpson) 93 D.T.C. 5281 (F.C.A), leave to appeal refused (1994), 167 N.R. 240n (S.C.C.). ...
FCTD
1853-9049 Quebec Inc. v. The Queen, 87 DTC 5093, [1987] 1 CTC 137, [1986] 2 CTC 486, [1987] DTC 5031 (FCTD)
I therefore considered on March 11, 1986 that it might reasonably be considered that giving 1853 time to pay the assessment made in respect of it for 1983 and 1984, in the amount of $3,096,556.98, would jeopardize the recovery, and I decided to order payment forthwith for the following reasons: (a) it appeared that 1853 paid no attention to the notice and warning from their accountants in October 1983 regarding its tax situation for 1983; (b) the accountant in fact said that the money might quickly be gone and we knew what we had to do; (c) on February 14, 1986 the directors settled their differences; (d) on the same day (February 14, 1986), despite a notice from the accountants regarding possible tax of $1,900,000 for 1983 and 1984, 1853 — sold debts totalling $1,608,000 in capital alone, bearing interest at 12% and over, and due partly in January 1987, partly in February 1988 and partly in February 1993; — obtained the sum of approximately $1,664,000 for this transfer; — declared and paid a dividend of some $4,500,000 to the personal management companies of Messrs. ... The assets referred to in paragraph (g) above are, in addition to the debt by the Caisse de dépôt et de placement, a promissory note for $1 million from the Crédit industriel Desjardins, bearing interest at 12.5 per cent and due on January 14, 1987, Commission scolaire Le Gardeur bonds in the amount of $608,000, bearing interest at 12 per cent and 12.5 per cent and due partly in February 1988 and partly in February 1993, except that this note and these bonds were transferred to Lévesque Beaubien Inc. on February 14, 1986 for approximately $1,664,000. ...
FCTD
Ellingson v. Canada (Minister of National Revenue), 2005 DTC 5492, 2005 FC 1068
Harris, [1993] B.C.J. No. 3140 (B.C. Prov. Ct.) aff'd [1995] B.C.J. ... " Whatever was the situations in 1992, 1993 or 1995, the program clearly had changed by 2002 into one focusing on civil audits rather than criminal investigations. ...
FCTD
Tedford v. Canada (Attorney General), 2006 FC 1334
Material attached to the Applicant’s “Petition” in fact dealt with his tax history for the years from 1993 to 2004 and highlighted critical events or “circumstances beyond his control” that he alleged impacted his ability to file returns on a timely basis throughout that period. ... REVIEWABLE ERROR [23] The applicant urges that the decision under review and the Respondent’s working papers leading to the decision indicate that the period in question in his request for relief is 1997 until 2003 whereas his request for relief relates to the period from 1993 to the present and that the Minister “…used the time of recovery after a series of extraordinary circumstances beyond the applicant’s control to inflict serious penalties and interest charges…” which was neither fair nor just ...
FCTD
Gajic v. Canada (Minister of National Revenue), docket T-673-98
Supreme Court, heard the matter in June of 1993 and, in reasons sympathetic to Mr. ... Chung [1993] 2 F.C. 42 at 57, in which the court considered the requirements for issue estoppel and adopted those set out by the House of Lords in Carl Zeiss Stiftung v. ...
FCTD
Canada v. Cragg & Cragg Design Group Ltd., docket T-2942-94
Cragg & Cragg appealed the Minister's decision to the Trade Tribunal on 19 October 1993. [10] The Defendant's appeal to the Trade Tribunal succeeded. ... As I have already pointed out, where there has been delay before the commencement of an action and here I have in mind both the 22 months it took the Minister to deal with the notice of objection between 1991 and 1993 and the last minute appeal of the Trade Tribunal's decision, it is incumbent on a plaintiff to get on with the litigation at a reasonably quick pace. ...
FCTD
Gajic v. Canada, docket T-673-98
Supreme Court, heard the matter in June of 1993 and, in reasons sympathetic to Mr. ... Chung [1993] 2 F.C. 42 at 57, in which the court considered the requirements for issue estoppel and adopted those set out by the House of Lords in Carl Zeiss Stiftung v. ...