Search - 德国民法典第1993条

The Queen, 93 DTC 54, [1993] 1 CTC 2168 (TCC)-- summary under Paragraph 227.1(2)(a) Summary Under Tax Topics- Income Tax Act- Section 227.1- Subsection 227.1(2)- Paragraph 227.1(2)(a) The Minister did not fulfil the precondition in s. 227.1(2)(a) when he filed a certificate that did not take into account the amount of a Part VIII refund that had been determined and assessed by the Minister on the same day. ...

Devor, 93 DTC 5098, [1993] 1 CTC 142 (FCA)-- summary under Section 29 Summary Under Tax Topics- Other Legislation/Constitution- Federal- Federal Courts Act- Section 29 A statement of claim seeking a declaration that waivers "extracted" from the taxpayer were void and a writ of certiorari quashing the reassessments based thereon, was struck out on the basis that the relief claimed was beyond the jurisdiction of the Court. ...

The Queen, 93 DTC 5351, [1993] 2 CTC 257 (FCA)-- summary under Subparagraph 40(2)(g)(ii) Summary Under Tax Topics- Income Tax Act- Section 40- Subsection 40(2)- Paragraph 40(2)(g)- Subparagraph 40(2)(g)(ii) No deduction was available under s. 50(1)(a) in respect of a loan made by a corporation to an affiliate in the absence of any evidence that the recipient of the loan would be able to repay it. ...

The Queen, 93 DTC 5035, [1993] 1 CTC 269 (FCA)-- summary under Subsection 110.4(1) Summary Under Tax Topics- Income Tax Act- 101-110- Section 110.4- Subsection 110.4(1) There was no statutory authority to allow an amendment of the taxpayer's original election which he now considered to be desirable as a result of the Crown's disallowance of most of his claim for an RRSP deduction for the year in question. ...

., 93 DTC 5199, [1993] 1 CTC 363 (FCA)-- summary under Context Summary Under Tax Topics- Statutory Interpretation- Context MacGuigan J.A. applied the "words-in-total-context approach" in finding that because Puerto Rico was a country for purposes of Regulations 5907(10)(b) and (c), it also should be considered to be a country for purposes of Regulation 5907(10)(a). ...

Adelman, 93 DTC 5376, [1993] 2 CTC 207 (FCTD)-- summary under Subsection 26(7) Summary Under Tax Topics- Income Tax Application Rules- Subsection 26(7) The failure of the taxpayer to make a purported election under s. 26(7) resulted in the cost of his shares being determined without reference to that subsection. ...

The Queen, 93 DTC 5339, [1993] 2 CTC 99 (FCTD)-- summary under Section 7 Summary Under Tax Topics- Other Legislation/Constitution- Charter (Constitution Act, 1982)- Section 7 A retroactive amendment to s. 110(1)(f)(iii) of the Act was not contrary to ss.7 and 15 of the Charter. ...

Castelli, 92 DTC 6556, [1993] 1 CTC 76 (Ont. Ct. GD)-- summary under Evidence Summary Under Tax Topics- General Concepts- Evidence The trial judge had improperly inferred that the evidence of the accused lacked credibility due to his failure to cooperate with the authorities and to give a sworn statement during the investigation setting forth the evidence which he later gave at trial. ...

MNR, 93 DTC 5453, [1993] 2 CTC 278 (FCA)-- summary under Evidence Summary Under Tax Topics- General Concepts- Evidence The trial judge had committed an error of law when he concluded that failure of the taxpayers to keep proper records of wages paid by them to employees was fatal to their claim for a corresponding deduction from income. ...

The Queen, 93 DTC 110, [1993] 1 CTC 2189 (TCC)-- summary under Canadian Manufacturing and Processing Profits Summary Under Tax Topics- Income Tax Act- Section 125.1- Subsection 125.1(3)- Canadian Manufacturing and Processing Profits The sale and leasing of tapes and microfiches containing technical data on Canadian oil wells which the taxpayer had gathered, edited and organized was eligible for the deduction. ...