Search - 德国民法典第1993条

MNR, 93 DTC 564, [1993] 2 CTC 2074 (TCC)-- summary under Subsection 256(2.1) Summary Under Tax Topics- Income Tax Act- Section 256- Subsection 256(2.1) A finding was made that none of the main reasons for the separate incorporation of the taxpayers involved tax savings given that they had been separately incorporated primarily for the purpose of market targeting, and that their separate existence also enhanced financing opportunities and the protection of family assets from certain financial risks. ...

., [1993] 1 WWR 639 (Alta. Q.B.)-- summary under Subsection 317(3) Summary Under Tax Topics- Excise Tax Act- Section 317- Subsection 317(3) The exception in s. 317(3) for the priority provisions of the Bankruptcy Act did not give secured creditors priority over Revenue Canada because Revenue Canada had issued its requirement to pay before the filing of the petition in bankruptcy, with the result that the property in question had ceased to be property of the debtor. ...

Lao, 93 DTC 5251, [1993] 2 CTC 25 (FCTD)-- summary under Paragraph 6(3)(c) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(3)- Paragraph 6(3)(c) An allowance of $22,500 which the taxpayer received to compensate him for a portion of the higher price he would have to pay for a house on moving from Edmonton to Toronto on the commencement of employment with his employer, was found not to be an employment benefit under s. 6(1)(a) or an amount referred to in s. 6(3)(c). ...

The Queen, 93 DTC 1251, [1993] 2 CTC 2982 (TCC)-- summary under Paragraph 7(1)(a) Summary Under Tax Topics- Income Tax Act- Section 7- Subsection 7(1)- Paragraph 7(1)(a) Although the taxpayers purported to exercise employee stock options and assign them for the exercise price to the purchaser of shares of the corporation at a time that the market price was well in excess of the exercise price, in fact, they were doing so as agent for the purchasers. ...

The Queen, 95 DTC 288, [1993] 2 CTC 3141 (TCC)-- summary under Subsection 164(4.1) Summary Under Tax Topics- Income Tax Act- Section 164- Subsection 164(4.1) The Tax Court could not consider the appeal of the taxpayer from a reassessment of the Minister made pursuant to s. 164(4.1) given that such reassessment was entirely consistent with the Tax Court judgment that it was implementing, and given that s. 18(2.4) provided that such judgment was final and conclusive and not open to question or review except by the Federal Court of Appeal. ...

The Queen, 93 DTC 469, [1993] 1 CTC 2727 (TCC)-- summary under Subsection 162(1) Summary Under Tax Topics- Income Tax Act- Section 162- Subsection 162(1) Because the penalty under s. 162(1) was to be calculated at the time the return was required to be filed, the penalty in this case was not eliminated by the subsequent carrying back to the taxation year in question of a non-capital loss arising in the subsequent taxation year. ...

The Queen, 93 DTC 927, [1993] 2 CTC 2227 (TCC)-- summary under Ownership Summary Under Tax Topics- General Concepts- Ownership The taxpayer failed to establish that a Liechtenstein "establishment" held a Toronto condominium as bare trustee for the taxpayer in light inter alia of evidence that under the relevant arrangements the taxpayer's spouse was required to approve any procedure taken with respect to the assets and funds of the establishment. ...

The Queen and the Minister of National Revenue, 93 DTC 5009, [1993] 1 CTC 15 (FCTD)-- summary under Section 18 Summary Under Tax Topics- Other Legislation/Constitution- Federal- Federal Courts Act- Section 18 The Court had jurisdiction to entertain an application seeking to prohibit the Minister from performing further audits of the taxpayer for the taxation years in question and from continuing his practice of issuing two employer remittance forms. ...

Timpson, 93 DTC 5281, [1993] 2 CTC 55 (FCA)-- summary under Subsection 31(1) Summary Under Tax Topics- Income Tax Act- Section 31- Subsection 31(1) A full-time doctor who also devoted about 35 to 40 hours per week to the business of raising purebred cattle for breeding purposes was not able to deduct losses of $36,695 and $43,477 in 1977 and 1978 without limitation. ...

Dow & Duggan Log Homes International (1993) Limited v. The Queen, 2019 TCC 280-- summary under Subsection 168(9) Summary Under Tax Topics- Excise Tax Act- Section 168- Subsection 168(9) meaning of deposit adopted Wong J quoted with approval the comments in T endances et Concepts as to what was a deposit, but then found that, given the lack of probative documentary evidence provided by the taxpayer, none of the amounts assessed by the Minister had been established to be deposits. ...