Search - 德国民法典第1993条

MNR, 93 DTC 516, [1993] 1 CTC 46 (TCC)-- summary under Personal Services Business Summary Under Tax Topics- Income Tax Act- Section 125- Subsection 125(7)- Personal Services Business The taxpayer, through the services of its shareholder, prepared advertising brochures and folders for various clients, and had the printing work done exclusively by a corporation ("Bourguignon") of which the shareholder previously had been styled an employee prior to the incorporation of the taxpayer. ...

The Queen, 92 DTC 6595, [1993] 1 CTC 21 (FCTD)-- summary under Subsection 44(1) Summary Under Tax Topics- Income Tax Act- Section 44- Subsection 44(1) "immediately before" interpreted purposively to refer to something broader than the instant before In August 1979 the taxpayer decided that she wished to have a portion of a farm then owned by her husband developed as a housing subdivision. ...

Burnet, Duckworth & Palmer, [1993] WWR 374, 8 BLR (2d) 280 (Alta. ...

Mutual Life Assurance Co. of Canada v. 837690 Ontario Ltd. (1993), 36 RPR (2d) 159 (Ont Ct J (GD))-- summary under Paragraph 20(1)(c) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c) The plaintiff held a mortgage which, in addition to providing for blended payments of principal and interest, also provided for the payment after each year (for which there was revenue in excess of $950,000) of an additional amount equal to 25% of the mortgagor's adjusted annual cash flow (defined as 56% of its gross revenue for the year minus its annual blended payments under the mortgage for the year). ...

The Queen, 93 DTC 5271, [1993] 2 CTC 76 (FCA)-- summary under Subparagraph 53(2)(c)(v) Summary Under Tax Topics- Income Tax Act- Section 53- Subsection 53(2)- Paragraph 53(2)(c)- Subparagraph 53(2)(c)(v) 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%. ...

Bank of Montreal, [1993] GSTC 36 (Nfld. S.C.T.D.)-- summary under Subsection 299(2) Summary Under Tax Topics- Excise Tax Act- Section 299- Subsection 299(2) assessment not a proceeding In its 3 June 1992 order appointing Coopers & Lybrand as the receiver-manager of an insolvent company (“Lundrigans”), the Newfoundland Supreme Court order “that no action, application or other proceedings…shall be taken against the Debtor…without the prior consent of the Receiver and Manager.” ...

The Queen, 93 DTC 1004, [1993] 2 CTC 2259 (TCC)-- summary under Paragraph 20(1)(c) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c) loss utilization was not income-producing purpose/ gross income test In order to utilize the losses of its U.S. subsidiary, the taxpayer borrowed funds in Canada from an arm's length bank and made a capital contribution of those funds to the U.S. subsidiary. ...

The Queen, 93 DTC 5052, [1993] 1 CTC 169 (FCTD)-- summary under Capital Loss v. ...

., [1993] 2 WLR 696 (PC)-- summary under Nature of Income Summary Under Tax Topics- Income Tax Act- Section 9- Nature of Income The taxpayer, who was a partner in a New Zealand professional accounting firm, assigned 40% of his units to the trustee of a trust for the benefit of his wife and child. ...

MNR, 93 DTC 1473, [1993] 2 CTC 3148 (TCC)-- summary under Regulation 2902 Summary Under Tax Topics- Income Tax Regulations- Regulation 2902 The taxpayer unsuccessfully argued that interest expenses incurred by it to finance the payroll cost of its R & D personnel were not made for the purpose of generating expenses, not income, and therefore were not described in Regulation 2902(a)(c). ...