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Decision summary
Kyard Capital 2007 Inc. v. Agence du revenu du Québec, 2019 QCCQ 1617 -- summary under Subsection 15(1)
After noting that the description of the legal services provided had not been revealed to the ARQ on the grounds of privilege, Chalilfour JCQ stated (at paras. 133-135, TaxInterpretations translation): Not waiving professional privilege could certainly render the reversing of the presumption of validity of an assessment … more difficult. ...
Decision summary
Unidisc Musique Inc.v. Agence du revenu du Québec, 2019 QCCQ 1818, rev'd 2021 QCCA 393 -- summary under Class 14.1
In fact, the quality of the sound recording had everything to do with the quality of the physical medium …. ...
Decision summary
Gagnon v. Amazon.com Inc., 2019 QCCA 1166 -- summary under Subsection 261(1)
If the alleged fault of the respondents rested solely on the erroneous collection of taxes on products sold, it could be concluded that the recourse sought attempted to circumvent the ETA and STA …. ...
Decision summary
National Car Parks Ltd v Revenue and Customs, [2019] EWCA Civ 854 -- summary under Consideration
A customer pays for parking in a car park of the appellant (NCP) by going to the ticket machine which, on its tariff board, displays a price for one hour of £1.40 – but also states that change is not given but overpayments are accepted. ...
Decision summary
Agence du revenu du Québec v. Teitelbaum, 2019 QCCA 1408 -- summary under Subsection 70(3)
. … In sum, I am of the view that the debt claim bequeathed to the Taxpayer was transferred to her on November, 12, 2008, being the date of death of Mr. ...
Decision summary
Denis v. Agence du revenu du Québec, 2019 QCCQ 6708 -- summary under Subparagraph 45(1)(a)(ii)
. … [N]o transformation or modification of much significance was made to the Triplex in order for the three units to be linked in some manner to each other. ...
Decision summary
Latulippe v. Agence du revenu du Québec, 2019 QCCA 2177 -- summary under Paragraph 45(1)(a)
He stated (at para. 64, TaxInterpretations translation): [T]he simple fact of wishing to obtain a better price on the sale of the immovable is insufficient for concluding that a taxpayer was engaged in an adventure or concern in the nature of trade; a taxpayer engaging in a project carrying risk or having a commercial character is not necessarily carrying on a business …. ...
Decision summary
Gestions Calce Ltée v. Agence du revenu du Québec, 2019 QCCQ 7377 -- summary under Former Business Property
Whether the property was a “former business property” turned on whether (under the definition thereof) it qualified as a “property … leased by the taxpayer to a person related to the taxpayer and used by that related person principally for any other purpose.” ...
Decision summary
Dare Human Resources Corporation v. Ontario (Revenue), 2019 ONCA 549 -- summary under Employer
The appeal judge did not … fail to consider any relevant factor. ...
Decision summary
BT Céramiques Inc. v. Agence du revenu du Québec, 2020 QCCA 402 -- summary under Subsection 24(1)
. … [It] simply could not take advantage of the proceeds of the illegally obtained warrants. ...