Search - 德国民法典第1993条

MNR, 93 DTC 939, [1993] 2 CTC 2370 (TCC)-- summary under Shares Summary Under Tax Topics- Income Tax Act- Section 9- Capital Gain vs. ...

The Queen, 93 DTC 1222, [1993] 2 CTC 2765 (TCC)-- summary under Subsection 15(2.4) Summary Under Tax Topics- Income Tax Act- Section 15- Subsection 15(2.4) Oral evidence by the individual's shareholder of his intent to repay money that had been advanced to him by a numbered corporation to construct a dwelling for his personal use was found by Sarchuk TCJ. to be "not evidence of an agreement creating enforceable rights and obligations but rather... an open ended arrangement in which the date of any repayment was wholly within the control of the borrower" (p. 1225). ...

The Queen, 93 DTC 1226, [1993] 2 CTC 2830 (TCC)-- summary under Improvements v. ...

MNR, 93 DTC 1511, [1993] 2 CTC 3003 (TCC)-- summary under Subsection 70(9) Summary Under Tax Topics- Income Tax Act- Section 70- Subsection 70(9) In finding that 50% of the lands of the deceased were used in the business of farming immediately before his death, rather than 10% as reassessed by the Minister, Gauron TCJ. stated (p. 1515) that he did not believe: "That in interpreting subsection 70(9) one must consider only the part of the land that was effectively used for tillage of the soil or other agricultural operations immediately before the taxpayer's death. ...

The Queen, 93 DTC 65, [1993] 1 CTC 2081 (TCC)-- summary under Improvements v. ...

MNR, 89 DTC 5464, [1990] 1 CTC 241 (BCCA), aff'd 93 DTC 5137, [1993] 2 SCR 53-- summary under Subsection 231.3(3) Summary Under Tax Topics- Income Tax Act- Section 231.3- Subsection 231.3(3) There is no right of appeal from an order made pursuant to s. 231.3. ...

The Queen, 93 DTC 1449, [1993] 2 CTC 3189 (TCC), ultimately aff'd 96 DTC 6309, [1996] 2 S.C.R. 161-- summary under Incurring of Expense Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Incurring of Expense S.18(1)(a) could not apply to deny a loss realized by the taxpayer on the sale of inventory acquired by it pursuant to an s. 88(1) wind-up of its subsidiary because inter alia the deemed cost of the land to the taxpayer under an s. 88(1) could not be characterized as an "outlay or expense" of the taxpayer. ...

MNR, 93 DTC 462, [1993] 2 CTC 3210 (TCC)-- summary under Paragraph 96(1)(f) Summary Under Tax Topics- Income Tax Act- Section 96- Subsection 96(1)- Paragraph 96(1)(f) partner could not also be an employee In the course of finding that a corporation, that provided the management services of an officer and specified shareholder ("Cipora") to two rental-property partnerships of which Cipora was also a partner, did not carry on a personal services business, Hamlyn J stated (at p. 466): [A] partner cannot be an employee of a partnership that is capable of entering into a contract of employment with the partnership and as a consequence an incorporated employee could not become an employee of a partnership [of which] the incorporated employee was a partner. ...

Lorimer, [1993] BTC 473 (C.A.)-- summary under Subsection 5(1) Summary Under Tax Topics- Income Tax Act- Section 5- Subsection 5(1) The special commissioner did not make any reversible error in finding that a "vision mixer" who undertook short engagements for a large number of television companies (generally 120 to 150 engagements per year typically lasting only one day), who incurred very substantial expenditures in the course of obtaining and organizing those engagements, and who took the risk of his fees becoming bad debts, was self-employed, notwithstanding that he did not risk any of his own capital in the various engagements. ...

MNR, 93 DTC 901, [1993] 2 CTC 2193 (TCC)-- summary under Disposition Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Disposition The taxpayers did not realize allowable business investment losses pursuant to their guarantees of obligations of a corporation where in the taxation year the bank obtained judgment against them on their guarantees and registered the judgments in the appropriate land titles office against lands owned by them. ...