Search - 制暴无限杀机 下载

In dismissing their appeal, Bouchard JCA indicated that the fact that this was an isolated transaction and that they were not “flippers” was not decisive, the judge had not erred in noting the complete absence of any business plan or other documentary proof of their lack of motivating intention to sell (although, he noted, at para. 34, TaxInterpretations translation, and before referring to Hickman Motors in this regard) that “it is true that there are exceptional situations where the taxpayer manages to demolish the ARQ's assumptions of fact despite the taxpayer’s evidence being limited to the taxpayer’s testimony”) and (at para. 44) that “the judge did not commit a reviewable error … by holding that the appellants had a secondary intention to divest themselves of their project in the event of an interesting offer being made to them.” ...

. … Given that the Federation became legally obligated to pay a “levy” for a year to CanLII once such levy and the corresponding levies on the provincial law societies, had been approved by its council, “the levy was paid by operation of law for the supply of the virtual library,” i.e., “[t]here was an obligation on the Federation to pay and payment was not discretionary as argued by the [Crown]” (para. 510. ...

The fourth (“JDF”) property was bought as a vacant lot in October 2009, he and his wife and children, during construction of a home thereon with the assistance of TSC, moved into the basement and then the main floor in August and November 2010, respectively – but the house was sold in June 2013 (with an October closing) due to financial pressure on the taxpayer resulting from a business downturn. ...

The Queen, 2020 TCC 116 (Informal Procedure), aff'd 2022 FCA 57-- summary under Recipient Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Recipient employees rather than employer were the recipients of health care services even where the employer paid the health care provider directly Westcoast reimbursed (through Manulife as its agent) employees who had incurred various health care services – including some which were GST/HST-taxable, namely, acupuncture, massage therapy, naturopathy and homeopathy services. ...

He and his spouse flew down to Las Vegas on a vacation, but he then rented a car so that he could drive down to Phoenix (accompanied by his spouse) so that he could attend to issues regarding the rental unit – then they flew directly from Phoenix back home (in Vancouver). ...

In finding that the taxpayer’s claimed losses (except for an $8 million overstatement of the 2002 loss due to an “egregious error” – for which a gross negligence penalty was sustained) were fully deductible, Spiro J noted (at para. 191): Friedberg stands for the proposition that straddle traders may report the results of their trades for tax purposes on a [realization] basis that does not reflect the true economic results of such trades.” ...

. … Unlike in Transocean, in my view, it would be patently unfair to the Appellants if the Minister could assume facts in support of the post-sale tax liability of the subsidiaries when the Appellants cannot reasonably be expected to know those facts. ...

. … The arrangement also requires that the orthodontist identify the consideration for the zero-rated supply of the appliance separately from the consideration for the exempt supply of services. ...

Accordingly, CRA disallowed the corporation’s input tax credit claims – effectively on the basis that there was a single supply of exempt orthodontic services. ...

. … They constitute benefits that the Principals enjoyed, to varying degrees, as a result of the Reorganization, but I have no doubt reduction of taxes was one of the main reasons for it. ...