Search - 德国民法典第1993条

MNR, 93 DTC 1473, [1993] 2 CTC 3148 (TCC)-- summary under Paragraph 20(1)(c) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c) In finding that interest costs incurred by the taxpayer to finance the payroll cost of its R & D personnel were described in s. 20(1)(c), Kempo, TCJ. stated (p. 1478): "That no income was or could have been gained or produced at that time from the property being researched and developed is not determinative because the purpose and direct use of the borrowed funds were focused to that end and no issues were raised concerning the efficacy of the projects under research. ...

The Queen, 93 DTC 5511, [1993] 1 CTC 31 (FCTD)-- summary under Transitional Provisions and Policies Summary Under Tax Topics- General Concepts- Transitional Provisions and Policies Strayer J. found that there had been a "transfer" within the broad meaning of s. 160(1) of a beneficial interest in the land to the taxpayer by her father prior to the introduction of the expanded version of s. 160(1) effective November 12, 1981 given that prior to that date her father had entered into a separation agreement with his wife binding him to transfer the land to his daughter. ...

The Queen, 93 DTC 5511, [1993] 1 CTC 31 (FCTD)-- summary under Subsection 160(1) Summary Under Tax Topics- Income Tax Act- Section 160- Subsection 160(1) Strayer J. found that there had been a "transfer" within the broad meaning of s. 160(1) of a beneficial interest in the land to the taxpayer by her father prior to the introduction of the expanded version of s. 160(1) effective November 12, 1981 given that prior to that date her father had entered into a separation agreement with his wife binding him to transfer the land to his daughter. ...

MNR, 93 DTC 347, [1993] 1 CTC 2343 (TCC)-- summary under Substance Summary Under Tax Topics- General Concepts- Substance substance based on analysis of agreement Before going on to find that an agreement, which was in the form of a lease, in substance was a sale agreement, Brulé J. stated (p.354) that: "It is evident from the case law that in determining the true character of an agreement between parties, the substance (as opposed to the form) of the agreement is of paramount importance. ...

The Queen, 93 DTC 438, [1993] 1 CTC 2284 (TCC)-- summary under Paragraph 7(1)(a) Summary Under Tax Topics- Income Tax Act- Section 7- Subsection 7(1)- Paragraph 7(1)(a) In order to evade limitations established by the Vancouver Stock Exchange as to the number of shares a stock promoter was permitted to have the right to acquire under option, a promoter entered into an arrangement with the taxpayer under which the taxpayer was granted employee stock options and agreed to sell a portion of the shares acquired by him under option to the promoter at the taxpayer's cost. ...

Carew, 92 DTC 6608, [1993] 1 CTC 1 (FCA)-- summary under Section 12 Summary Under Tax Topics- Other Legislation/Constitution- Federal- Tax Court of Canada Rules (General Procedure)- Section 12 The Crown served its reply to the taxpayer's notice of appeal on the 60th day required by Rule 44(1) but, due to an unexplained failure of the subordinate employee, the reply was not presented for filing until the following day. ...

., [1993] BTC 291 (D)-- summary under Paragraph 111(5)(a) Summary Under Tax Topics- Income Tax Act- Section 111- Subsection 111(5)- Paragraph 111(5)(a) Vice-Chancellor Nicholls affirmed the finding of the Commissioner that the purchase as a going concern by the taxpayers of an existing fish and chip shop business in a village five miles away, followed by the continued conduct of that business from the same premises but with substantial variations in the mode of conduct thereof should be characterized as an expansion by the taxpayers of their own fish and chip business into the new premises, rather than as a continuation of the trade carried on by the former owner at the new premises. ...

., 93 DTC 5199, [1993] 1 CTC 363 (FCA)-- summary under Evidence Summary Under Tax Topics- General Concepts- Evidence A certificate provided by the Secretary of State for External Affairs of Canada that Puerto Rico was a political subdivision of the United States of America was found to have application only to the question of state immunity in Canadian courts. ...

The Queen, 93 DTC 5179, [1993] 1 CTC 234 (FCTD)-- summary under Subsection 194(4) Summary Under Tax Topics- Income Tax Act- Section 194- Subsection 194(4) A related corporation issued a non-interest bearing promissory note for $120,000 to the taxpayer on May 18, 1984. ...

The Queen, 93 DTC 5285, [1993] 2 CTC 47 (FCTD)-- summary under Paragraph 152(4)(b) Summary Under Tax Topics- Income Tax Act- Section 152- Subsection 152(4)- Paragraph 152(4)(b) The Crown was unable to establish that an assessment issued on December 28, 1981 in respect of the July 30, 1980 taxation year of the taxpayer should instead be regarded as an assessment of the corporation (having a different name) with which the taxpayer amalgamated on July 31, 1980. ...