Search - 德国民法典第1993条

The Queen, 95 DTC 311, [1993] 2 CTC 3125 (TCC)-- summary under Subsection 80(1) Summary Under Tax Topics- Income Tax Act- Section 80- Subsection 80(1) promissory note enforceable A promissory note that the taxpayer had given as consideration for a limited partnership interest acquired by him was found to be a legally enforceable claim of the banks to which it had been assigned. ...

Devor, 93 DTC 5098, [1993] 1 CTC 142 (FCA)-- summary under Section 18 Summary Under Tax Topics- Other Legislation/Constitution- Federal- Federal Courts Act- Section 18 The Federal Court had no jurisdiction to declare that waivers, which allegedly had been extracted from the taxpayer under compulsion and duress, were void. ...

Sinclair, 93 DTC 5239, [1993] 2 CTC 70 (FCTD)-- summary under Retirement Savings Plan Summary Under Tax Topics- Income Tax Act- Section 146- Subsection 146(1)- Retirement Savings Plan The RRSP of the taxpayer was found to be subject to execution pursuant to s. 7(1) of the Executions Act (Manitoba). ...

MNR, 94 DTC 1603, [1993] 2 CTC 3009 (TCC)-- summary under Start-Up and Liquidation Costs Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Start-Up and Liquidation Costs Expenses claimed by the taxpayer as soft costs in respect of condominium investments were found to have been incurred prior to the date of acquisition of the condominiums (notwithstanding that they were paid as "adjustments" at the time of closing), with the result that they were non-deductible to the taxpayers. ...

The Queen, 93 DTC 995, [1993] 2 CTC 2247 (TCC), aff'd 96 DTC 6544 (FCA)-- summary under Income-Producing Purpose Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Income-Producing Purpose A debt to the taxpayer from a non-resident corporation, which arose because of the taxpayer's inadvertent failure to withhold from interest payments made to the non-resident and which the taxpayer was unable to collect, was not deductible and did not relate to a deductible expenditure. ...

The Queen, 93 DTC 5058, [1993] 1 CTC 99 (FCTD)-- summary under Subsection 194(4.2) Summary Under Tax Topics- Income Tax Act- Section 194- Subsection 194(4.2) The requirements of s. 194(4.2)(b) were met given that the steps that had been taken by April 10, 1984 "were meaningful, significant and advanced", including an identified research and development project on which money already had been spent, a budget, and discussions with a third-party financier, evidenced in writing, with a request that the project be funded by way of an SRTC issue. ...

MNR, 93 DTC 451, [1993] 1 CTC 2710 (TCC)-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development A supposed research project which folded after the initial phases of work and therefore consisted only of routine data collection and research in the educational area did not qualify as scientific research described in Regulation 2900. ...

The Queen, 93 DTC 201, [1993] 1 CTC 2066 (TCC)-- summary under Subparagraph 8(1)(h)(ii) Summary Under Tax Topics- Income Tax Act- Section 8- Subsection 8(1)- Paragraph 8(1)(h)- Subparagraph 8(1)(h)(ii) The taxpayer was able to establish that an automobile was the most practical and most reasonable way for him to perform his duties as a "checker" for the Montreal Urban Transit Authority, with the result that he was entitled to deduct his automobile expenses. ...

The Queen, 93 DTC 438, [1993] 1 CTC 2284 (TCC)-- summary under Substance Summary Under Tax Topics- General Concepts- Substance Before rejecting a submission that the taxpayer should be regarded as having received options on behalf of another person notwithstanding the form of the documents, Bonner J. stated (p. 441): "Any conclusion as to the substance of a transaction must rest not on words chosen by the parties to describe the transaction or on some loose or imprecise view of what the transaction amounted to. ...

MNR, 93 DTC 603, [1993] 1 CTC 2634 (TCC)-- summary under Qualified Expenditure Summary Under Tax Topics- Income Tax Act- Section 127- Subsection 127(9)- Qualified Expenditure The Minister was unsuccessful in a submission that the qualified expenditures of the taxpayer should be reduced by the amount of income derived by it from the sale of experimental production. ...