Search - 制暴无限杀机 下载

In this regard, he stated (at paras. 54-55): l’École polytechnique … 2004 FCA 127, confirms that the reasonable diligence defence can be used against an administrative penalty established under the scheme of section 280 of the ETA [stating]: [D]ue diligence excuses either a reasonable error of fact, or the taking of reasonable precautions to comply with the Act. ...

Graham J then stated (at para. 26, obiter): [I]f the reassessment in question [instead] had been made after the normal reassessment period … it would be inappropriate for me to attribute knowledge of that revocation to Mr. ...

. … I do not see any practical difference between a law being given retroactive effect and a fact deemed by law to exist retroactively being given retroactive effect. ...

The Queen, 2018 TCC 3, aff'd on s. 18(1)(a) grounds 2019 FCA 36-- summary under Income-Producing Purpose Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Income-Producing Purpose purpose of payment was to extricate from a regional economic-development obligation rather than to enhance business reputation The corporate taxpayer agreed with the City of Chandler that it would no longer use any loan repayment proceeds received by it from a City-owned corporation- that had failed in an costly attempt to restart a paper mill close to the City – to invest in a prospective replacement economic-development LP to be sponsored by the City, but would instead make a “gift” of the loan repayment proceeds (which ended up totalling $9.3 million) to the City, for which it received charitable receipts. ...

In finding that the appellant was making taxable supplies, D’Arcy J first stated (at para. 88) that it was “providing something,” which was “the service of collecting, recycling and/or safely disposing of the MHS Waste (the “Recycling Services”),” and that (para. 89) it “provide[d] the Recycling Services to the persons who physically possessed the MHS Waste prior to its collection by the Appellant and to the MHSW Stewards, who … had a statutory obligation to incur the cost of collecting and recycling the MHS Waste.” ...

The taxpayer in fact “engaged in no acts of management … let alone any actions specific to a director” (para. 40). ...

A previous case had found that generally “dismissal under section 16.2 of the TCC Act carries the same effect as a judgment of dismissal by the Court” – and the action which thus had constructively been decided against them was one in which they could have, but failed to, raised their statute-barring arguments. ...

The Queen, 2009 TCC 588 that: None of [the cited cases], however, support the appellant’s proposition that adjustments to the expenses of a previous fiscal period, and concomitant changes to the income of the employee for a previous year, may be made on a retroactive basis …. ...

In rejecting a taxpayer submission that s. 256(1.2)(f)(ii) should be interpreted as providing only that the affected beneficiaries were deemed to hold 24.99% of the shares held by the trusts, and finding that they instead were deemed by s. 256(1.2)(f)(ii) to hold 100% of such shares (so that the appellant corporations were associated), Lamarre ACJ stated (at paras. 54, 56, TaxInterpretations translation): Nothing indicates that subparagraph 256(1.2)(f)(ii) will not apply if the discretionary share of a beneficiary is limited by the deed of trust …. ...

The Queen, 2018 TCC 85-- summary under Subsection 104(1) Summary Under Tax Topics- Income Tax Act- 101-110- Section 104- Subsection 104(1) Quebec trusts are considered to be owners of their property for ITA purposes The taxpayers, in connection with arguing (at para. 62) that the reference in the preamble to s. 256(1.2)(f)(ii) to “shares … owned.. by a trust” should be interpreted as referring only to shares that had been earmarked under the deed of trust for the beneficiaries, went on to argue (para. 1261) that, having regard to Art. 1261 of the Civil Code, a Quebec trust was not the owner of the property in its patrimony. ...