Search - 德国民法典第1993条

., 93 DTC 5116, [1993] 1 CTC 346 (FCA)-- summary under Paragraph 39(5)(a) Summary Under Tax Topics- Income Tax Act- Section 39- Subsection 39(5)- Paragraph 39(5)(a) "trader or dealer" need not be licensed In rejecting the taxpayer's submission that s. 39(5)(a) should be limited to persons who are registered or licensed by regulatory authorities to buy and sell securities, Létourneau J.A. stated (p. 5120) that: "The words 'trader or dealer in securities'... are broad enough to include anyone other than a person engaged in an adventure or concern in the nature of trade" Words and Phrases trader or dealer in securities ...

., 93 DTC 5116, [1993] 1 CTC 346 (FCA)-- summary under Legislative History Summary Under Tax Topics- Statutory Interpretation- Legislative History Létourneau J.A. indicated that his view, that the phrase "trader or dealer in securities" in s. 39(5) was not restricted to dealers who are registered under provincial securities laws, was supported by the subsequent addition of section 47.1 to the Act, which confined that phrase to persons who are registered or licensed under the laws of a province to trade in securities. ...

Silden, 93 DTC 5362, [1993] 2 CTC 123 (FCA)-- summary under Interpretation Bulletins, etc. ...

MNR, 93 DTC 92, [1992] 2 CTC 2673, [1992] 2 CTC 2208, [1993] DTC 88 (TCC)-- summary under Real Estate Summary Under Tax Topics- Income Tax Act- Section 9- Capital Gain vs. ...

The Queen, 93 DTC 965, [1993] 2 CTC 2658 (TCC)-- summary under Subsection 244(14) Summary Under Tax Topics- Income Tax Act- Section 244- Subsection 244(14) The assumption by another corporation ("Polar Oils") of the obligation of the taxpayer to pay $119,658 in consideration for the taxpayer's agreement to pay four cents per litre more for diesel fuel purchased by it from Polar Oils until the total overpayments amounted to $119,658, constituted an inducement under s. 12(1)(x). ...

The Queen, 93 DTC 904, [1993] 2 CTC 2165 (TCC)-- summary under Subsection 227(10.1) Summary Under Tax Topics- Income Tax Act- Section 227- Subsection 227(10.1) An assessment for tax owing by the taxpayer under s. 116(5) that was issued beyond the normal reassessment was statute-barred. ...

MNR, 93 DTC 250, [1993] 1 CTC 2279 (TCC)-- summary under Evidence Summary Under Tax Topics- General Concepts- Evidence After noting (at p. 254) that "the role of expert witnesses is to provide impartial assistance to a court, particularly when complex issues of a scientific or technical nature are involved", Sarchuk TCJ. indicated that he had reservations as to evidence of two experts that a hypothetical fact situation (approximating the facts being asserted by the taxpayer) described a direct financial leases. ...

Leung, 93 DTC 5467, [1993] 2 CTC 284 (FCTD)-- summary under Subsection 152(3) Summary Under Tax Topics- Income Tax Act- Section 152- Subsection 152(3) reassessment valid notwithstanding missing particulars A reassessment of a director in respect of the aggregate amount of source deductions which the corporation had failed to make under the Act and three other statutes which did not separately disclose the amounts purportedly owing under each statute, and that referred for further details to an assessment which had been made on the corporation, nonetheless was valid in light of ss.152(3) and (8) of the Act and the fact that it contained all the essential ingredients for a notice of assessment. ...

Leung, 93 DTC 5467, [1993] 2 CTC 284 (FCTD)-- summary under Subsection 227.1(1) Summary Under Tax Topics- Income Tax Act- Section 227.1- Subsection 227.1(1) A reassessment of a director in respect of the aggregate amount of source deductions which the corporation had failed to make under the Act and three other statutes which did not separately disclose the amounts purportedly owing under each statute, and that referred for further details to an assessment which had been made on the corporation, nonetheless was valid in light of ss.152(3) and (8) of the Act and the fact that it contained all the essential ingredients for a notice of assessment. ...

MNR, 93 DTC 758, [1993] 1 CTC 2522, [1992] 1 CTC 2553 (TCC)-- summary under Subparagraph 152(4)(a)(i) Summary Under Tax Topics- Income Tax Act- Section 152- Subsection 152(4)- Paragraph 152(4)(a)- Subparagraph 152(4)(a)(i) mere misinterpretation of the Act The taxpayer did not make a misrepresentation attributable to carelessness or wilful default in following a cash basis of accounting rather than accrual basis of accounting or in treating advances made by him as running expenses. ...