Search - 临汾市2天旅游行程
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TCC (summary)
Reid v. MNR, 91 DTC 1443, [1991] 2 CTC 2715, [1991] 2 CTC 2697 (TCC) -- summary under Paragraph 118(1)(a)
MNR, 91 DTC 1443, [1991] 2 CTC 2715, [1991] 2 CTC 2697 (TCC)-- summary under Paragraph 118(1)(a) Summary Under Tax Topics- Income Tax Act- Section 118- Subsection 118(1)- Paragraph 118(1)(a) A man who had been the common law spouse of the taxpayer for thirty years was not a "spouse" for purposes of the Income Tax Act. ...
TCC (summary)
Campeau v. MNR, 93 DTC 92, [1992] 2 CTC 2673, [1992] 2 CTC 2208, [1993] DTC 88 (TCC) -- summary under Real Estate
MNR, 93 DTC 92, [1992] 2 CTC 2673, [1992] 2 CTC 2208, [1993] DTC 88 (TCC)-- summary under Real Estate Summary Under Tax Topics- Income Tax Act- Section 9- Capital Gain vs. ...
TCC (summary)
Tétrault v. MNR, 92 DTC 2240, [1992] 2 CTC 2787, [1992] 2 CTC 2125, [1992] DTC 2235 (TCC) -- summary under Ownership
MNR, 92 DTC 2240, [1992] 2 CTC 2787, [1992] 2 CTC 2125, [1992] DTC 2235 (TCC)-- summary under Ownership Summary Under Tax Topics- General Concepts- Ownership It was found that by an agreement dated January 16, 1985, the taxpayer had disposed of his shares of a corporation to a shareholder. ...
TCC (summary)
Mara Properties Ltd. v. The Queen, 93 DTC 1449, [1993] 2 CTC 3189 (TCC), ultimately aff'd 96 DTC 6309, [1996] 2 S.C.R. 161 -- summary under Incurring of Expense
The Queen, 93 DTC 1449, [1993] 2 CTC 3189 (TCC), ultimately aff'd 96 DTC 6309, [1996] 2 S.C.R. 161-- summary under Incurring of Expense Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Incurring of Expense S.18(1)(a) could not apply to deny a loss realized by the taxpayer on the sale of inventory acquired by it pursuant to an s. 88(1) wind-up of its subsidiary because inter alia the deemed cost of the land to the taxpayer under an s. 88(1) could not be characterized as an "outlay or expense" of the taxpayer. ...
TCC (summary)
Caithkin Inc. v. The Queen, 2014 TCC 80, aff'd 2015 FCA 118 -- summary under Section 2
The Queen, 2014 TCC 80, aff'd 2015 FCA 118-- summary under Section 2 Summary Under Tax Topics- Excise Tax Act- Schedules- Schedule V- Part IV- Section 2 resupply of foster-care services The appellant ("Caithkin") worked as an intermediary in the foster-care system, by finding suitable foster homes for various Children's Aid Societies and placing children there and providing related training and supervisory services. ... Graham J found that Caithkin had not provided an exempt supply under s. 2 of Part IV of Sched. V, as it satisfied only two of the three requirements of s. 2: Caithkin was making a "re-supply" to the Societies of "care, supervision and place of residence services" that it in turn "acquire[d] from the foster parents" (TCC para. 24). ...
TCC (summary)
Sunshine Coach Ltd v. The Queen, 2019 TCC 72 (Informal Procedure) -- summary under Section 2
The Queen, 2019 TCC 72 (Informal Procedure)-- summary under Section 2 Summary Under Tax Topics- Excise Tax Act- Schedules- Schedule VI- Part VII- Section 2 Alberta bus tours were not part of continuous journey performed outside Canada The appellant was an Alberta-incorporated tour operator based out of Calgary that operated tour bus trips between a resort in Banff (“Sunshine Village”) and Alberta locations (usually Calgary or Canmore), although some of its charter services were for trips outside of Canada. ... VII, s. 2 was not available, Campbell J found that, as there was no evidence that any of the disputed transportation services were provided outside of Canada, accordingly, the services are not zero-rated under s. 2 because neither the origin nor termination of any of those trips or any stopovers in respect to the services provided by the Appellant were outside Canada. ...
TCC (summary)
Victus Academy LP v. The Queen, 2020 TCC 134 (Informal Procedure) -- summary under Section 2
The Queen, 2020 TCC 134 (Informal Procedure)-- summary under Section 2 Summary Under Tax Topics- Excise Tax Act- Schedules- Schedule V- Part III- Section 2 hockey program qualified as an exempt "course" The appellant (“Victus Academy”) operated a for-profit private school in Kitchener, Ontario that provided students in grades 7 through 12 with both hockey and academic programs within typical school hours. ... III, s. 2 or s. 3, given that the students came within the definition in Sched. ... Regarding the s. 2 exemption, she stated (at paras. 39, 40): Section 2 does not specify the nature of the courses that are exempt. … … [S]ection 16 of Part III refers to instructing individuals in courses “other than courses in sports, games, hobbies or other recreational pursuits that are designed to be taken primarily for recreational purposes ”. ...
TCC (summary)
Canada- Israel Development Ltd. v. MNR, 85 DTC 718, [1985] 2 CTC 2460 (TCC) -- summary under Article 24
Section 2 of the Protocol to the Treaty provided: Nothing in this Convention shall be construed as preventing Canada from imposing tax on amounts included in the income of a resident of Canada according to section 91 of the Canadian Income Tax Act... ... However, s. 2 of the Protocol indicated that the Treaty did not prevent Canada from imposing tax on residents of Canada under the FAPI rules and that the Treaty did not require Canada to give relief for foreign tax if those rules applied. Accordingly, the taxpayer was not entitled to a deduction under ITA s. 91(4) by virtue of the prohibition in s. 2. ...
TCC (summary)
Université Laval v. The Queen, 2016 TCC 17 -- summary under Section 2
The Queen, 2016 TCC 17-- summary under Section 2 Summary Under Tax Topics- Excise Tax Act- Schedules- Schedule V- Part VI- Section 2 agreement to licence sports complex in futre to City inhabitants was a real property supply Tardif J found that two agreements under which Quebec City agreed to pay a $10M grant to Laval University for the expansion of its sports complex and the University agreed that the City populace would have access to the complex for 70% of its operating hours constituted a supply by the University in consideration for the $10M. ... V, Pt VI, s. 2. ...
TCC (summary)
Wassick v. MNR, 95 DTC 19, [1994] 2 CTC 2235 (TCC) -- summary under Subsection 2(1)
MNR, 95 DTC 19, [1994] 2 CTC 2235 (TCC)-- summary under Subsection 2(1) Summary Under Tax Topics- Income Tax Act- Section 2- Subsection 2(1) The taxpayer, who worked abroad (primarily in Scotland) as a deep-sea diver but who frequently returned to Canada where he had friends and relatives and a relationship that ultimately culminated in a common-law union, was found to be ordinarily resident in Canada. ...