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10 February 1993 T.I. 921720C (See also 13 January 1993 T.I. 923304) -- summary under Paragraph 12(1)(x)

10 February 1993 T.I. 921720C (See also 13 January 1993 T.I. 923304)-- summary under Paragraph 12(1)(x) Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(1)- Paragraph 12(1)(x) Amounts paid to Atlantic hog farmers were repayable, except that "if certain conditions subsequent are met they may be forgiven". ...

8 January 1993 T.I. 922776 (November 1993 Access Letter, p. 503, ¶C109-155; Tax Window, No. 28, p. 5, ¶2367) -- summary under Non-Qualifying Real Property

8 January 1993 T.I. 922776 (November 1993 Access Letter, p. 503, ¶C109-155; Tax Window, No. 28, p. 5, ¶2367)-- summary under Non-Qualifying Real Property Summary Under Tax Topics- Income Tax Act- 101-110- Section 110.6- Subsection 110.6(1)- Non-Qualifying Real Property Real property owned equally by two unrelated individuals that is leased by them to a corporation owned equally by them to be used by it in carrying on its active business will not qualify because, in the case of each individual, the shares owned by him will not represent all or substantially all the fair market value of all the issued and outstanding shares of the corporation. ...

12 January 1993 T.I. 922833 (November 1993 Access Letter, p. 506, ¶C117-208; Tax Window, No. 28, p. 28, ¶2368) -- summary under Total Charitable Gifts

12 January 1993 T.I. 922833 (November 1993 Access Letter, p. 506, ¶C117-208; Tax Window, No. 28, p. 28, ¶2368)-- summary under Total Charitable Gifts Summary Under Tax Topics- Income Tax Act- Section 118.1- Subsection 118.1(1)- Total Charitable Gifts A gift (i.e., a voluntary transfer of property without consideration and without conditions) is considered to occur where an individual has paid more for an annuity purchased from a charity than the total amounts expected to be received as annuity payments. ...

Régime De Rentes Pour Les Employés De Direction De Gestion R.S.T. Inc. v. Minister of National Revenue, [1993] 2 CTC 2001, [1993] 1 CTC 2091, [1993] DTC 670, [1993] DTC 672

Minister of National Revenue, [1993] 2 CTC 2001, [1993] 1 CTC 2091, [1993] DTC 670, [1993] DTC 672 Lamarre Proulx, T.C.C.J. ...

Philippe Weiller v. Minister of National Revenue, [1993] 1 CTC 2117, [1993] DTC 686, [1993] 1 CTC 2480, [1993] DTC 692

Minister of National Revenue, [1993] 1 CTC 2117, [1993] DTC 686, [1993] 1 CTC 2480, [1993] DTC 692 Tremblay, T.C.C.J. ...

Claude Tousignant v. Minister of National Revenue, [1993] 1 CTC 2250, [1993] DTC 522, [1993] 1 CTC 2461, [1993] DTC 530

Minister of National Revenue, [1993] 1 CTC 2250, [1993] DTC 522, [1993] 1 CTC 2461, [1993] DTC 530 Tremblay, T.C.C.J.:— This appeal was heard in Quebec City on April 28, 1992. 1. ...

Williams, "The Finance Act 1993: Incredible Drafting, Extraordinary Prose", British Tax Review, 1993, No. 6, p. 483. -- summary under Drafting Style

Williams, "The Finance Act 1993: Incredible Drafting, Extraordinary Prose", British Tax Review, 1993, No. 6, p. 483.-- summary under Drafting Style Summary Under Tax Topics- Statutory Interpretation- Drafting Style ...

Roberts, "The Agency Element of Permanent Establishment: The OECD Commentaries from the Civil Law View", International Tax Review, September 1993, p. 396, and October 1993, p. 488. -- summary under Article 5

Roberts, "The Agency Element of Permanent Establishment: The OECD Commentaries from the Civil Law View", International Tax Review, September 1993, p. 396, and October 1993, p. 488.-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 ...

Watkins, "Equity Exchangeable Debentures and Appreciation Rights", 1993 Conference Report, C. 20; and Kingissepp, "Summaries of Corporate Finance Panel Discussion", 1993 Conference Report, C. 21 -- summary under Subsection 49(1)

Watkins, "Equity Exchangeable Debentures and Appreciation Rights", 1993 Conference Report, C. 20; and Kingissepp, "Summaries of Corporate Finance Panel Discussion", 1993 Conference Report, C. 21-- summary under Subsection 49(1) Summary Under Tax Topics- Income Tax Act- Section 49- Subsection 49(1) Discussion of whether s. 49 applied to an offering of "appreciation rights" by Canadian Pacific. ...

Lise Naud, Serge Naud, Michel Daigle v. Minister of National Revenue, [1993] 1 CTC 2008, [1992] 1 CTC 2760, [1993] DTC 286, [1993] DTC 288

Minister of National Revenue, [1993] 1 CTC 2008, [1992] 1 CTC 2760, [1993] DTC 286, [1993] DTC 288 Tremblay, T.C.C.J. ...

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