Search - 制暴无限杀机 下载

. … The time limits for the assessment and collection of the tax debt are all expressly provided for in the TA and the TAA. ...

. … If the Minister agrees with Mr. Turski, and indeed with me, that the application of the 36-month rule in this case seems to lead to an unfair and unreasonable result, and that the public interest that led to the adoption of that rule does not apply in this case- and I hope the Minister will so agree- then the Minister will ask Cabinet to approve the remission order. ...

. … I [also] do not believe it is in the public interest that I decide on an issue without hearing evidence that is relevant to the determination as to whether or not the exclusions apply. ...

. … Regarding the IPT, section 527 of the QSTA clearly provides that the insurer, in its capacity as agent, must account for the tax collected in the preceding calendar month at the end of the month. ...

. … There is a direct link between the PCB Points that are issued in conjunction with an exempt financial service supplied by PC Bank to Cardholders and an expense that is paid when the PCB Points are redeemed by Cardholders. ...

. … In this case, the appellants could revoke the designation of R3D as beneficiary at any time, but this is a right that flows from the insurance contract. ...

. … In also finding that the Court below had not erred in declining to exercise its residual discretion to permit the ITC claims (viewed as a post-filing claim) against the tax owing, he stated (at para. 48) that this would have been “inconsistent with the remedial objectives of the CCAA, regardless of whether the focus is on restructuring the debtor’s affairs or on liquidation.” ...

Before remitting the adverse decision of the CRA review officer for decision by another officer, Southcott J noted that the CRA position- that the taxpayer had not made a reasonable error (the first element of s. 204.1(4)) given that the taxpayer was notified of his contribution on a sufficiently timely basis that he could have gone back to RBC to correct its reporting of the contribution while it still had sufficient records of the transaction – was not supported by the record, which did not establish that CRA had notified the taxpayer of his alleged over-contribution in 2013 before December 2020. ...

. … [I]n tax matters, where the federal and provincial provisions are appreciably in the same form, a presumption of coherence between the two provisions should prevail. ...

. … Further, once the respondents were swayed to buy into WTC’s plan by the thought of turning an unexpected profit out of their crystallized tax liability through what they viewed as a risk-free exercise, they became the instruments through which WTC, acting as the sole mastermind, would lay its hands on the $1.3 million [equal to the tax liability], isolate it with the remaining cash in the subsidiaries and share it with the respondents in the proportion that it imposed. ...