Search - 德国民法典第1993条

The Queen 1993 CanLII 55 (SCC), [1993] 4 S.C.R. 695, para. 74 (“ Symes ”): As in other areas of the law where purpose or intention behind actions is to be ascertained, it must not be supposed that in responding to this question courts will be guided only by a taxpayer’s statement ex post facto or otherwise, as to the subjective purpose of a particular expenditure. ...

The appellant stated her husband was born in India but came to Canada in 1993. ... In 1993, she began working as an ICO in Surrey. She does not speak Punjabi. ... She stated other labour contractors had been hired prior to 1993 but they contracted with Bant in 1993 and thereafter each year until the end of the 1996 season. ...

He started working for Alberta Government Telephones (AGT)- the predecessor of Telus- in 1993. ... Since joining Telus in 1993, he had always been assigned a free parking pass and considered it “absolutely essential” in order to provide him with the opportunity to commute during the day and visit clients such as CP Hotels that owned or operated facilities in various locations, including Banff or to attend at the Calgary Airport Authority offices or at Telus pay phone offices in Calgary. ... There had been layoffs in 1993 – and a hiring freeze imposed- but the amount of work was the same and remaining employees had to work harder. ...

., 2013 SCC 37 at para 19. [88] At paragraph 2. [89] Mueller Canada Inc. v State Contractors Inc. (1989), 71 OR (2d) 397 (Ont HCJ). [90] At paras 12-13. [91] Stevenson v Reimer, [1993] OJ No 2440 (Ont Gen Div) at para 16; Seanco Investments Inc. v Betovan Construction Ltd., [2006] OJ No 274 (Ont SCJ) at paras 43-44 and 47; Sabre Inc. v International Air Transport Assn., [2009] OJ No 903 (ONSC) at para 22. [92] [1996] 1 FC 756. [93] At para 26. [94] [2000] FCJ No 127 (FCTD). [95] At para 16. [96] 2008 TCC 500. [97] See para 3. [98] 2006 SCC 39. [99] At para 36. [100] At paras 38-40. [101] At para 49. [102] (1999), 45 OR (3d) 321 (ONCA). [103] [1969] 2 Ex CR 27. [104] Sidney N. ... Realty Ltd. (1983), 11 CPC (3d) 147 (BCCA) at para 5; Canada (Minister of Citizenship and Immigration) v Dueck (1998), 146 FTR 89 (FCTD); and Canada (Minister of National Revenue) v Thornton, 2012 FC 1313. [109] 2014 ABCA 289. [110] At para 8. [111] AR 124/2010. [112] At para 54. [113] At para 60. [114] At para 70. [115] At para 72. [116] 2014 TCC 45. [117] See paras 58-62. [118] Solid Waste Reclamation Inc. v Philip Enterprises Inc., [1991] OJ No 213, 2 OR (3d) 481 (Ont Gen Div). [119] See Cameco Corp. at para 61. [120] Second Edition, February 2015 at Section 1.F.5, page 7. [121] GRI Simulations Inc. v Oceaneering International Inc., 2010 NLTD 85 at para 25. [122] Canada v GlaxoSmithKline Inc., 2012 SCC 52. [123] Ontario Public Service Employees Union Pension Trust Fund (Trustees of) v Clark (2005), 77 OR (3d) 38 (SCJ), aff’d, (2006), 270 DLR (4 th) 429 (CA), particularly at para 67. [124] IKEA Ltd. v Canada, [1993] TCJ No. 874, at paras 13 and 18. [125] 2013 TCC 404. [126] See para 275. [127] [1993] TCJ No. 874, at paras 13 and 18. [128] 2010 OECD Transfer Pricing Guidelines, para 1.36, 1.59-1.63. [129] Callinan Mines Ltd. v Hudson Bay Mining and Smelting Co., 2011 MBQB 159, and Ontario Public Service Employees Union Pension Trust Fund (Trustees of) v Clark (2005), 77 OR (3d) 38 (SCJ), aff’d, (2006), 270 DLR (4 th) 429 (CA). [130] Rivtow Straits Ltd. v B.C. ...

The Queen, [1993] T.C.J. No. 213 (QL), [1993] 2 C.T.C. 2087, at para. 35 ...

Cockburn had been a leased NLS employee since 1993 and was placed with Anduhyaun in the position of Children’s Programmer. ... However, she had participated in certain benefits offered in her contract dated January 21, 1993, pursuant to which she was placed at Anduhyaun as a Residential Counsellor. ...

Sometime between 1993 and 1995, Pocido and another builder developed approximately 20 townhouses in Squamish, British Columbia. ... Wall reported income as follows for the purposes of the Act between 1987 and 2010: [28] Year Amount 1987 $11,266 1988 $27,552 1989 $8,076 1990 $21,879 1991 $10,412 1992 $107,678 1993 $15,303 1994 $600 1995 $43,419 1996 $50,887 1997 $35,248 1998 $23,000 1999 $15,000 2000 $7,000 2001 $13,472 2002 $29,000 2003 $15,000 2004 $15,806 2005 $18,000 2006 $26,036 2007 $15,919 2008 $15,547 2009 $16,646 2010 $15,684   [80]   In 2005, Mr. ...

Canada, (1993) [1994] 1 CTC 3 (FCA) (“ Pollock ”), R. v. Loewen, 2004 FCA 146 (“ Loewen ”), Anchor Pointe 2003, Orly Automobiles Inc. v. ... The Court observed: An amalgamation was necessary for Copthorne to achieve the outcomes it sought in 1993 when it undertook the transactions between VHHC Holdings, Copthorne I and Big City—a simplification of the corporate structure, and the ability to shelter anticipated gains with losses within the four amalgamating corporations. ...

Berg, [1993] 2 S.C.R. 353, at p. 371.  As Professor Sullivan has wisely observed, even when the broad purposes of legislation are clear, “it does not follow that the unqualified pursuit of those purposes will give effect to the legislature’s intention”: R. ...

R. (1993), [1994] 1 C.T.C. 40 (S.C.C.), is clear that if the expenses are business in nature, instead of personal, the test for deductibility may be met by showing the expense satisfied a need of the company. ...