Search - 制暴无限杀机 下载

At the time the plaintiff filed his return in April 1999 for his 1998 taxation year, he did not retain a taxable benefit resulting from his conduct for which he ultimately was found to be criminally responsible …. ...

The following question was posed under Rule 58 of the Tax Court of Canada Rules (General Procedure): Where the Minister has at all times concluded that no partnership existed, can the Minister issue a valid Notice of Determination in respect of that purported partnership under subsection 152(1.4) …. ...

In summarizing this arrangement, Hogue, J.C.A. stated (at para. 42, TaxInterpretations translation): … [T]he agreed formula means that PCI must repay the advances received over 15 years if its revenues are stable. ...

The open court principle allows any person to inspect a court record and any annex "that is available to the public" …. ...

Monaghan J stated (at para. 213): … The Tax Court will address all challenges to the correctness of the assessment made after the transfer pricing provisions have been applied, including whether the conditions for their application are met, the amount of any adjustments, the liability for penalties and whether the Minister exercised her discretion properly. ...

Harris filing returns showing employment and dividend income from 405 Canada – and although those returns were filed after 405 Canada’s VDP application, “[i[t would be incongruous” for the 405 Canada disclosure to be rendered voluntary “simply because a related taxpayer did not file the returns that would reveal the same information until after filing a VDP application” (para. 19). the possibility mentioned by CRA in its enforcement letter of arbitrarily assessing Mr. ...

Smith J indicated (at para. 522) that: [T]he T3GR Return was the prescribed form intended by CRA to meet the filing requirements of RRSP trustees pursuant to paragraph 150(1)(c) and subsection 207.2(1) of the Act and section 204 of the Regulations and … it was intended as a streamlined process for the reporting of group RRSPs involving hundreds of thousands of plans under one specimen plan. ...

The ARQ reassessed to deny the deduction by Mobile of legal and accounting fees incurred by it in investigating the disappearance of the sales proceeds and in relation to the Superior Court action, primarily on the basis that they were capital expenditures (TA, s. 129, similar to ITA s. 18(1)(b) – although TA s. 128, similar to ITA s. 18(1)(a), was also invoked). ...

The information is required to verify the compliance of the taxpayer being audited and no application for judicial authorization is required …. ...

. … They are an exchange device because they may be used as consideration for property or services in the same way as money or a gift certificate. ...