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BCSC decision
Attorney General of Canada on Behalf of Her Majesty the Queen in Right of Canada as Represented by the Minister of National Revenue v. Avalon Developments Limited, Molnar Construction Limited and 942 Holdings Limited, [1994] 1 CTC 404
However, in a responding affidavit filed in support of the application to have my August 9, 1993 order set aside, Mr. ... In oral reasons, pronounced at the end of the August 9, 1993 hearing, I characterized the various advances as "maneuverings". ... For the above reasons, I am not prepared to set aside my order of August 9, 1993. ...
BCSC decision
Kranz v. Canada (Attorney General), [1999] 4 CTC 93
The alleged offences under the Income Tax Act were that Kranz Investments Ltd. and Frederick Kranz wilfully evaded or attempted to evade payment of taxes by under-stating the income of Kranz Investments Ltd., that Kranz Investments Ltd. and Frederick Kranz had made or participated in, assented to or acquiesced in the making of false or deceptive statements in the 1994, 1995 and 1996 income tax returns of Kranz Investments Ltd., that Yaletown Enterprises Ltd. and Katarina Kranz had wilfully evaded or attempted to evade payment of taxes imposed on Yaletown Enterprises Ltd. for the taxation years 1993 and 1994 and had unlawfully made or participated in, assented to or acquiesced in the making of false or deceptive statements in the 1993 and 1994 corporation income tax returns for Yaletown Enterprises Ltd., that Frederick Kranz had evaded payment of taxes imposed upon him personally in his income tax returns for 1993 through 1995 and had made or participated in, assented to or acquiesced in the making of false or deceptive statements in his income tax returns for 1993 through 1995 and that Frederick Kranz and Katarina Kranz had wilfully evaded or attempted to evade payment of taxes imposed upon Katarina Kranz for the taxation years 1993 through 1995, that Frederick Kranz and Katarina Kranz had unlawfully made, or participated in, assented to, or acquiesced in the making of false or deceptive statements in the 1993 through 1995 income tax returns of Katarina Kranz and that Katrina Grimmova conspired with Frederick Kranz and Katarina Kranz to enable Katarina Kranz to evade the payment of taxes in the 1994 taxation year and to commit an offence as described in paragraph 239(1)(d) of the Income Tax Act. Specifically, it was alleged that Frederick Kranz appropriated monies from Kranz Investments Ltd. in the amount of not less than $138,123 during the period January I, 1993 through December 31, 1995 by charging personal and non-business expenses to that company, that Katarina Kranz appropriated monies from Yaletown Enterprises Ltd. in the amount of not less than $111,910 during the period January 1, 1993 through December 31, 1995 by under-reporting the company’s rental income in 1993, by underpaying the company for renovations done on her personal residence and by under-reporting her income from the company in 1995, that Frederick Kranz under-stated his taxable income for the years 1993 through 1995 by failing to report the amount he appropriated from Kranz Investments Ltd., that Katarina Kranz under-stated her taxable income reported for the years 1993 through 1995 by failing to report the amount she appropriated from Yaletown Enterprises Ltd., that Frederick Kranz and Katarina Kranz understated the taxable income of Katarina Kranz reported for the 1994 taxation year when Katarina Kranz failed to report her income in the amount of $217,410 from the sale of property at 524 Eastcot Road, West Vancouver, that Frederick Kranz under-stated the revenues and over-stated the expenses of Kranz Investments Ltd. in an amount of not less than $138,123, that Frederick Kranz and Katarina Kranz under-stated the revenues and overstated the expenses of Yaletown Enterprises Ltd. in an amount of not less than $99,910 for the 1993 and 1994 taxation years and that Katrina Grim- mova conspired with Frederick Kranz and Katarina Kranz in the understatement of the 1994 taxable income of Katarina Kranz by claiming ownership of 524 Eastcot Road, West Vancouver, and entitlement to the principle residence exemption available to such an owner. ... In those affidavits he states that the firm of Russell & DuMoulin was retained by him in 1993 and acted as legal counsel for him as well as Kranz Investments Ltd. and Yaletown Enterprises Ltd., the firm of Clark Wilson was retained by him in 1993 and acted as legal counsel for him and the two companies through 1996, the firm of Thorsteinssons was retained by him in 1997 and has since acted as legal counsel for him, Katarina Kranz and the two companies in respect of certain income tax matters, David Okros was retained by him in 1993 and acted as legal counsel for him and the two companies and, that David Okros, representatives from Russell & DuMoulin, Clark Wilson and Thorsteinssons had confidential communications with him in his personal capacity and his capacity as an officer of the two companies for the purpose of seeking or obtaining legal advice and that Katarina Kranz has had confidential communications with representatives from Thorsteinssons for the purposes of seeking or obtaining legal advice. ...
BCSC decision
Her Majesty the Queen v. Michael Vukelich, [1994] 1 CTC 152
CC930183) on February 25, 1993. I agree with those reasons with respect and gratitude. ... Wittrup, [1993] B.C.W.L.D. 1108, February 24, 1993, (S.C.) Vancouver Registry No. ...
BCSC decision
Fraser & Beatty v. Minister of National Revenue, [1994] 1 CTC 267
By letter dated July 20, 1993, the Minister of National Revenue issued a "requirement" pursuant to paragraphs 231.2(1)(a) and (b) of the Act requesting that the petitioner provide documents concerning this transaction. ... T & N pic. (1993), 77 B.C.L.R. (2d) 391, [1993] 4 W.W.R. 709 (C.A.). ...
BCSC decision
San Diego Catering, Re, [1996] 1 CTC 61
Facts On March 26, 1993, San Diego Catering Ltd. (“San Diego”) filed a proposal with the trustee, Campbell, Saunders Ltd. (the trustee”) which was accepted by the creditors of San Diego at a meeting held on August 15, 1993. ... Bank of Montreal (1993), 21 C.B.R. (3d) 120, in support of the proposition that the deemed trust provision in the Income Tax Act relates only to principal and does not apply to penalties and interest. ...
BCSC decision
Kevin Radke and K.J.R. Development Group Ltd. v. Minister of National Revenue, [1996] 3 CTC 86
He notes that it is only for the years subsequent to 1991 that K.J.R. indicates a splitting of profits and exhibits the 1992 and 1993 return in support. ... Further, that she did not report any such income in her 1992 or 1993 T1 returns which were electronically filed. ...
BCSC decision
Jarman v. Canada, [1998] 3 CTC 398
., on Form T-2, including a balance sheet and an income statement for the fiscal period ended during 1993; (iii) an Income Tax Return of Bee True Ventures Ltd., on Form T-2, including a balance sheet and an income statement for the fiscal period ended during 1994; (b) in the alternative, an order stipulating that, as these proceedings arose out of Port Alberni, British Columbia, that they be held and conducted at Port Alberni, British Columbia, and not at Victoria, British Columbia. ... He is alleged to have failed to file a personal income tax return for 1994 and tax returns for the business for 1993 and 1994 as required by the Income Tax Act. ...
BCSC decision
Deputy Minister of National Revenue (Taxation) v. Kung, [1999] 1 CTC 48
Landru (1992), [1993] 1 C.T.C. 93 (Sask. Q.B.). Respondent’s Submissions (L14/R3512/T0/BT0) test_marked_paragraph_end (2104) 1.034 0078_7899_8065 In brief, the respondent says that the order was properly made on the material before the court and on the relevant provisions of the Act and the case authorities. ...
BCSC decision
R. v. Vinkle, [1999] 2 CTC 212
The first information included five counts pertaining to the taxation years 1990 to 1993, and the second included six counts pertaining to the taxation years 1987 to 1994. ... Count 4: Ronald Stewart Vinkle, on or about December 31, 1994 at the village of Kaslo and elsewhere in the Province of British Columbia, unlawfully failed to provide a signed Income Tax Return on Form T1 for the taxation year ended December 31, 1993, as required pursuant to the provisions of paragraph 231.2(1)(a) of the Income Tax Act, and did thereby commit an offence contrary to the provisions of subsection 238(1) of the said Act. Count 5: Ronald Stewart Vinkle, on or about December 31, 1994 at the village of Kaslo and elsewhere in the Province of British Columbia, unlawfully failed to provide a signed Statement of his Assets and Liabilities as at December 31, 1993, as required pursuant to the provisions of paragraph 231.2(1)(a) of the Income Tax Act, and did thereby commit an offence contrary to the provisions of subsection 238(1) of the said Act. ...
BCSC decision
Kenneth E.G. Taves v. Her Majesty the Queen, [1995] 2 CTC 347
The law firm was served by Revenue Canada Taxation with two letters dated April 30, 1993. ...