Search - 德国民法典第1993条

Shaw, 93 DTC 5121, [1993] 1 CTC 221 (F.C.A.)-- summary under Paragraph 44(2)(a) Summary Under Tax Topics- Income Tax Act- Section 44- Subsection 44(2)- Paragraph 44(2)(a) The farm lands of the taxpayer were expropriated pursuant to the Expropriation Act (Alberta) in 1977. ...

MNR, 93 DTC 291, [1993] 1 CTC 2429 (TCC)-- summary under Paragraph 6(1)(a) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a) The taxpayer, who was the employee of a company that assembled and sold tour packages, was found to have received a taxable benefit equal to the average cost to the company of airline seats which it chartered when the company provided to the taxpayer, along with other employees, the right to use seats which the company had been unable to sell to customers. ...

Canada, 94 DTC 6001, [1993] 4 S.C.R. 695, [1994] 1 CTC 40-- summary under Income-Producing Purpose Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Income-Producing Purpose unnecessary to consider whether should be change to traditional position that child care expenses were non-deductible Before indicating that it was unnecessary to determine whether there should be a change in the traditional position that child care expenses (in this case, the expenses of a nanny paid by a mother who practised law full-time as a partner in a Toronto firm) were non-deductible, Iacobucci J. noted that the character of child care expenses was unique. ...

Canada, 94 DTC 6001, [1993] 4 S.C.R. 695, [1994] 1 CTC 40-- summary under Purpose/Intention Summary Under Tax Topics- General Concepts- Purpose/Intention purpose to be determined having regard to objective manifestations thereof In the course of a general discussion of the purpose test in s. 18(1)(a), Iacobucci J stated: As in other areas of law where purpose or intention behind actions is to be ascertained, it must not be supposed that in responding to this question, courts will be guided only by a taxpayer's statements, ex post facto or otherwise, as to the subjective purpose of a particular expenditure. ...

.), briefly aff'd [1993] GSTC 10 (Man. C.A.)-- summary under Section 224 Summary Under Tax Topics- Excise Tax Act- Section 224 A contract which a municipality entered into with a contractor in the fall of 1989 that provided that the price to be paid to the contractor for its services in collecting garbage would include "all applicable duty, freight, cartage, Federal and Provincial Taxes and charges governmental or otherwise paid" was found not to exclude an additional charge by the contractor for GST, given the failure of the contract to add the phrase "whether in effect or hereafter imposed", in light of the contra proferentem doctrine, and in light of evidence that the contractor had informed the municipality, before it accepted the tender, that future GST was not included in the contract price. ...

MNR, 93 DTC 680, [1993] 1 CTC 2176 (TCC)-- summary under Paragraph 20(1)(c) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c) The taxpayer was given the opportunity to purchase 10.25% of the shares of a private company ("Choisy") for which he worked. ...

The Queen, 93 DTC 5271, [1993] 2 CTC 76 (FCA)-- summary under Disposition Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Disposition partial disposition of partnership interest to a related corporation, even though proceeds run through the partnership The other partners of the partnership consented to a reduction in the taxpayer's partnership interest from 40% to 15%, and to an increase in the partnership interest of a corporation ("WBG") of which he had voting control from 10% to 35%. ...

Boger Estate, 93 DTC 5276, [1993] 2 CTC 81 (FCA)-- summary under Paragraph (g) Summary Under Tax Topics- Income Tax Act- 101-110- Section 108- Subsection 108(1)- Trust- Paragraph (g) meaning of "vested" and "indefeasible" Heald JA summarized findings of the trial judge (p. 5279), which he later adopted (at p. 5281) as being "accurately stated": that an interest is vested if (a) the person entitled to it is ascertainable and, (b) that person can take possession forthwith and can only be prevented from doing so by the existence of some prior interest. ...

Re Koo, [1993] 1 F.C. 286, 1992 CanLII 2417 (T.D.)-- summary under Subsection 2(1) Summary Under Tax Topics- Income Tax Act- Section 2- Subsection 2(1) In finding that the appellant, who was physically present in Canada for 232 days during the four-year period preceding his application for citizenship, did not fulfil the requirement in s. 5(1) of the Citizenship Act of having accumulated "at least three years of residence in Canada" in that four-year period, Reed J. stated (p. 300): "Some of the appellant's extended family is here, but it is not possible to say that Canada is the main focus of the appellant's family life. ...

MNR, 93 DTC 999, [1993] 2 CTC 2244 (TCC)-- summary under Subsection 152(2) Summary Under Tax Topics- Income Tax Act- Section 152- Subsection 152(2) Notices of reassessment that were sent by registered mail by the Minister were returned by the post office, with the envelopes marked "unclaimed". ...