Search - 德国民法典第1993条

The Queen, 93 DTC 953, [1993] 2 CTC 2409 (TCC)-- summary under Subsection 165(3) Summary Under Tax Topics- Income Tax Act- Section 165- Subsection 165(3) Beaubier, J. followed the decision in Apfelbaum v. ...

The Queen, 93 DTC 953, [1993] 2 CTC 2409 (TCC)-- summary under Agency Summary Under Tax Topics- Income Tax Act- Section 9- Agency- Agency A wife was found not to have engaged in transactions (which were part of an arrangement for income splitting with her husband) as agent for her husband given that she was motivated by a desire for more income for herself and was a more enthusiastic participant in the transactions than her husband. ...

Loewen, 93 DTC 5109, [1993] 1 CTC 212 (FCTD)-- summary under Subsection 39(4) Summary Under Tax Topics- Income Tax Act- Section 39- Subsection 39(4) In finding that a purported election made by the taxpayer only after an audit by Revenue Canada was invalid, Dubé J. stated (p. 5115): "... ...

The Queen, 93 DTC 235, [1993] 1 CTC 2411 (TCC)-- summary under Paragraph (g) Summary Under Tax Topics- Income Tax Act- Section 66.1- Subsection 66.1(6)- Canadian exploration expense- Paragraph (g) An underground mining operation was a new mine rather than an expansion of the open pit mine which lay above it, given that it constituted a separate and a distinct extraction facility. ...

MNR, 93 DTC 358, [1993] 2 CTC 2136 (TCC)-- summary under Subsection 129(4.1) Summary Under Tax Topics- Income Tax Act- Section 129- Subsection 129(4.1) In upholding the contention of the taxpayer ("Mid-Western") that income from surplus cash invested in short-term deposits gave rise to Canadian investment income, Christie A.C.J. accepted evidence that "a financial relationship of dependence did not exist between the funds to generate the interest in dispute and the active business carried on by Mid-Western". ...

Canada, 94 DTC 6001, [1993] 4 S.C.R. 695, [1994] 1 CTC 40-- summary under Subsection 63(1) Summary Under Tax Topics- Income Tax Act- Section 63- Subsection 63(1) Because the purpose for which the taxpayer incurred her child care expenses came squarely within the definition of "child care expenses" in s. 63(3), she was precluded from deducting such expenses in accordance with the more general rules governing deductibility in ss.9 and 18(1)(a). ...

The Queen, 93 DTC 295, [1993] 1 CTC 2435 (TCC)-- summary under Cost of Labour Summary Under Tax Topics- Income Tax Regulations- Regulation 5202- Cost of Labour The taxpayer, which used employees throughout the year to manufacture and erect modular buildings, was able to treat amounts paid to subcontractors for the same work during the months of May to August of each year, when it tripled its production in order to manufacture portable school rooms, as the cost of labour. ...

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

The Queen, 93 DTC 552, [1993] 2 CTC 2330 (TCC)-- summary under Subsection 160(1) Summary Under Tax Topics- Income Tax Act- Section 160- Subsection 160(1) It was found that the taxpayer had a 50% interest in property transferred to her by her husband on the basis of there being either a resulting trust or constructive trust in relation to such property. ...

The Queen, 93 DTC 5412, [1993] 2 CTC 173 (FCTD)-- summary under Paragraph 8(1)(b) Summary Under Tax Topics- Income Tax Act- Section 8- Subsection 8(1)- Paragraph 8(1)(b) Legal expenses (but not interest thereon) paid by a dismissed member of the Alberta Union of Public Employees in connection with a grievance before an arbitration board resulting in his reinstatement were deductible. ...