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ABPC decision
Her Majesty the Queen v. Whissell-McLeod Ventures Ltd. And George Whissell, [1993] 1 CTC 89
And George Whissell, [1993] 1 CTC 89 Mustard, P.C.J.:—On November 1991, Revenue Canada Taxation issued and served six demands under paragraph 231.2(1)(a) on both the corporate accused ("the corporation”) and George Whissell ("VVhissell"), whereby each accused was required to provide within 75 days, signed T2 income tax returns for the corporation for each of its fiscal years ending December 31, 1986 to 1990 inclusive. ...
ABPC decision
Her Majesty the Queen v. Alex Dean Olson, [1993] 1 CTC 393
Alex Dean Olson, [1993] 1 CTC 393 Nemirsky, J.:—Alex Dean Olson is charged with 19 counts under the Income Tax Act, R.S.C. 1952, c. 148 (am. ...
ABPC decision
Her Majesty the Queen v. Delbert Fisher, Joyce M. Fisher, and Aubrett Holdings Ltd., [1993] 1 CTC 374
., [1993] 1 CTC 374 Hamilton, J.:—Delbert Fisher, Joyce Fisher, and Aubrett Holdings Ltd. ...
ABPC decision
Her Majesty the Queen v. Silvio Solano, Salt & Pepper Mexican Restaurant Limited and 370259 Alberta Limited, Sometimes Operating as the Red Iguana Mexican Restaurant, [1995] 2 CTC 497
Until the GST funds owing were seized by Revenue Canada in the fall of 1993, there was at least $70,000 that could have been applied for accounting work. ... He knew in November 1993, that the accountant, Daphne Wadlin, could not do the requisite accounting within the 90 day time period specified. ... His initial passive participation was not substantially changed once he received the notices to file in November 1993. ...
ABPC decision
Her Majesty the Queen v. Aulakh, Narinder Aulakh and Megal International Ltd., [1995] 2 CTC 526
Facts: The two accused individuals were served by Revenue Canada with four demands pursuant to subsection 231.2(1) of the Income Tax Act to file, within 90 days from service on April 6, 1993, individual returns for the years 1988 to 1991 inclusive, while a similar demand was served upon the corporate accused and the accused Narinder Aulakh in his capacity as its Director to file a corporate income tax return for the 1991 year. ... They did not comply with those requests in a timely manner and on April 6, 1993, they were properly served with the formal paragraph 231.2(l)(a) notices to file such returns marked as Exhibits herein. ... Several meetings and telephone calls were exchanged between the Revenue Canada officer and the accused persons in their individual capacity and with the male accused, in his representative capacity as Director of the corporate accused, all between October 1992 and April 1993, relating to their respective tax liabilities for the years in question. ...