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FCTD
Mohammad v. R., 97 DTC 5503, [1997] 3 C.T.C. 321 (FCA)
For the 1992 and 1993 tax years, the losses diminished to $4,000 and $1,000. ... Ministere du Revenu national, [1993] 2 C.T.C. 2494 (T.C.C.), appealed on other grounds,(1994), [1995] 2 F.C. 3 (Fed. ...
FCTD
Bozzer v. Canada, 2010 DTC 5025 [at at 6612], 2010 FC 139, rev'd 2011 DTC 5106 [at 5922], 2011 FCA 186
Canada, [1993] 4 S.C.R. 695, 44 A.C.W.S. (3d) 824 and held that “[o]nly a reasonable doubt, not resolved by the ordinary rules of interpretation, will be settled by recourse to the residual presumption in favour of the taxpayer” (Notre-Dame de Bon Secours at p. 20). ... Second, subsection 45(4) of the Interpretation Act submits that legislative provisions that have been repealed should be treated as if they never existed, as is the case with subsection 127(5) of the Income Tax Act, S.C. 1993, c. 24 ...
FCTD
Apv Canada Inc. v. Canada (Minister of National Revenue), 2001 FCT 737
By September of 1993 I had come to the conclusion that some form of legal action might be necessary to resolve these matters but there were still about 400 applications in respect of which no decision had yet been rendered. 33. ... The Cameron matter was commenced as Federal Court action T-2340-93 [sic] on September 15, 1993. ...
FCTD
Capital Records v. Canada, docket T-2541-94
By Notices of Decision dated March 31, 1993 the Notices of Objection were disallowed by the Minister on the basis that Capitol Records and Kensington operated as a single economic entity and no sale had occurred. 5. Capitol Records appealed the Notices of Decision to the CITT on or about May 26, 1993. ...
FCTD
SHELL CANADA PRODUCTS LIMITED v. HER MAJESTY THE QUEEN, 2002 FCT 1304
E-15. [2] SOR/98-106. [3] Subsection (1): S.C. 1993, c. 25, s. 55. ... E-15. [7] [1981] 2 S.C.R. 437 "> [1981] 2 S.C.R. 437. [8] (2001), 206 F.T.R. 278. [9] [1993] 3 S.C.R. 463. [10] (1983), 37 D.T.C. 5301 (F.C.A.). [11] House of Commons Debates, Official Report, First Session- 30 th Parliament, Vol. ...
FCTD
Fox Lake Indian Band v. Reid Crowther & Partners Ltd., 2002 FCT 630
Canada (1993) 93 D.T.C. 298 were considered by Mr. Justice Lemieux in Hoechst Marion Roussel Deutchland GmbH v. ... Canada (1993) 164 N.R. 301 (F.C.A.) "... that amendment should not be denied when one is dealing with an area of the law that cannot be said to be settled with certainty. ...
FCTD
Jack Cewe Ltd. v. Canada, docket T-3390-90
Ministre du Revenu National, [1993] 72 F.T.R. 175. [31] The plaintiff submits that the Minister's power under s. 28(1)(d) is not entirely subjective or arbitrary and must be exercised by the Minister "within the four corners of his jurisdiction'. ... Minister of National Revenue (Customs and Excise) (1993), 71 F.T.R. 199 [" Sunbeam "], in which the court held that it was not relevant how various taxpayers are treated as tax liability must be determined under the Act. ...
FCTD
Chevron Canada Resources Ltd. v. Canada (Minister of National Revenue), docket T-2268-98
A Status Hearing for the applicant's appeal was held on November 19, 1993 and a trial date was set for September 14, 1994. ... The applicant filed, on December 20, 1993, an Amended Notice of Appeal in the Tax Court action withdrawing the issue of deductibility of royalties in respect to liquified petroleum gases ("LPG"). ...
FCTD
Canada (Minister of National Revenue) v. Moss, docket T-166-97
The respondent's husband was reassessed for the 1991, 1992 and 1994 years and for tax debt from the 1987, 1990, 1993 and 1995 in the amount of $301,956.21. [16] The respondent's husband made an assignment into bankruptcy on September 6, 1996. ... Numerous deposits were made for payment of the Erinview, McIvor, 129 Park Place, 121 Park Place and 51 Dumbarton properties. [18] A series of negotiated cheques, written by the respondent between October 28, 1993 and February 12, 1996 show that the respondent had transferred $477,470.50 from her account to NN Life Insurance and Equitable Life. ...
FCTD
Reebok Canada v. Canada (National Revenue), docket T-864-94
.: This is an appeal from a decision of the Canadian International Trade Tribunal ("CITT") dated September 1, 1993 by which certain payments made by the appellant, in accord with exclusive distribution agreements, were determined to be part of the value for duty and therefor dutiable under the Customs Act, R.S.C. 1985, c.1 (2nd supp.). ... The appeal from the decision of the CITT, rendered on September 1, 1993, is dismissed. _________________________________ JUDGE Ottawa, Ontario June 30, 1997. ...