Search - 德国民法典第1993条

Her Majesty the Queen, [1993] 2 CTC 2756-- summary under Subsection 15(2.6) Summary Under Tax Topics- Income Tax Act- Section 15- Subsection 15(2.6) journal entry made after the s. 15(2.6) deadline did not have retroactive effect At issue was whether an amount, which was lent to the taxpayer, who was "connected" with a shareholder of the corporation (“Steel”), was repaid within one year from the end of the taxation year of Steel, which had made the loan, for the purposes of what was then s. 15(2)(b. ...

MNR, 93 DTC 427, [1993] 1 CTC 2746 (TCC)-- summary under Subsection 55(2) Summary Under Tax Topics- Income Tax Act- Section 55- Subsection 55(2) Two brothers (the "Mazzoccas"), who constituted two of the three equal shareholders of a corporation ("Tri-M"), transferred their shares of Tri-M on a partial rollover basis to two holding companies and caused the two holding companies to purchase the shareholding of the third shareholder ("Manley"). ...

MNR, 93 DTC 889, [1993] 2 CTC 2447 (TCC)-- summary under Class 29 Summary Under Tax Topics- Income Tax Regulations- Schedules- Schedule II- Class 29 containers used for sorting materials essential to their processing The taxpayer, which derived its revenues from contracts for the demolition of buildings or other works, and from the sale of materials resulting from its alleged processing activities on the demolition sites, successfully maintained its position that its recycling activities, i.e., sorting materials, cutting to size, taking out the hardware, separating various items, removing nails and screws, etc., were processing activities. ...

The Queen, 93 DTC 5351, [1993] 2 CTC 257 (FCA)-- summary under Subsection 56(2) Summary Under Tax Topics- Income Tax Act- Section 56- Subsection 56(2) benefit concurred in by taxpayer was not taxable under s. 56(2) as it was taxable to the recipient At a time that the taxpayer was an officer, director, and 49% shareholder of an incorporated Ford dealership ("Holiday 77"), Holiday 77 transferred a substantial portion of its business assets to a new corporation ("Holiday 80") whose shares were owned as to 20% by the taxpayer and as to the remaining 80% by Ford Motor Company of Canada. ...

Dow & Duggan Log Homes International (1993) Limited v. The Queen, 2019 TCC 280-- summary under Section 12 Summary Under Tax Topics- Excise Tax Act- Schedules- Schedule VI- Part V- Section 12 CRA does not have the discretion to stipulate the documentary requirements for the s. 12 zero-rating CRA assessed on the basis that sales by the appellant of log homes were not zero-rated under Sched. ...

Boger Estate, 93 DTC 5276, [1993] 2 CTC 81 (FCA)-- summary under Subsection 70(9) Summary Under Tax Topics- Income Tax Act- Section 70- Subsection 70(9) conditional devise was sufficient to constitute a transfer of the property The will of the deceased taxpayer devised a life interest in some lands (the "home quarter") to his wife and the residue of his estate (including some additional lands) to his four children. 2 1/2 years after his death his wife obtained a court order pursuant to the Family Relief Act (Alberta) granting her the fee simple in the home quarter. ...