Search - 制暴无限杀机 下载

Nomad Sand & Gravel Ltd., 87 DTC 5343, [1987] 2 CTC 112 (FCTD)-- summary under Class 22 Summary Under Tax Topics- Income Tax Regulations- Schedules- Schedule II- Class 22 A sand and gravel pit was not a "mine", and front end loaders used in the gravel pit operation accordingly were Class 22, rather than Class 10 assets. ...

& J. Music Ltd., 80 DTC 6219, [1980] CTC 287 (FCTD)-- summary under Subsection 165(1) Summary Under Tax Topics- Income Tax Act- Section 165- Subsection 165(1) A taxpayer was not entitled to appeal from a determination of its cumulative deduction account where the amount of tax for the year was not affected. ...

Smith, Kline & French Laboratories Ltd. v. A.G. (Can.), 89 DTC 5205, [1989] 2 CTC 63 (FCTD)-- summary under Onus Summary Under Tax Topics- General Concepts- Onus There is a common law presumption in support of public access to the courts and court records, and the burden of persuading the court that access should not be provided is upon the person who seeks to deny it. ...

Canadian & Foreign Securities Co. Ltd. v. MNR, 72 DTC 6354, [1972] CTC 391 (FCTD)-- summary under Paragraph 108(2)(b) Summary Under Tax Topics- Income Tax Act- 101-110- Section 108- Subsection 108(2)- Paragraph 108(2)(b) Demand loans made to a company which were evidenced by unsecured promissory notes were found to be "securities" for purposes of the definition of "investment company" in s. 69(2) of the pre-1972 Act. ...

Terra Mining & Exploration Ltd. (N.P.L.), 84 DTC 6185, [1984] CTC 176 (FCTD)-- summary under Scheme Summary Under Tax Topics- Statutory Interpretation- Scheme Since s. 20(1)(c) was thought to be almost a mirror image of s. 12(1)(e), case law as to the meaning of the latter was found to be relevant to the meaning of the former. ...

Peter Cundill & Associates Ltd. v. The Queen, 91 DTC 5085, [1991] 1 CTC 197 (FCTD), aff'd 91 DTC 5543 (FCA)-- summary under Interpretation Bulletins, etc. ...

Canadian Propane Gas & Oil Ltd. v. MNR, 73 DTC 5019, [1972] CTC 566 (FCTD)-- summary under Section 67 Summary Under Tax Topics- Income Tax Act- Section 67 With respect to the statutory predecessor of s. 68, Cattanach J. stated (p. 5028): "I should think that 'reasonable' as used in the context of section 20(6)(g) does not mean from the subjective point of view of the Minister alone or the appellant alone, but rather from the point of view of an objective observer with the knowledge of all the pertinent facts. ...

R & W Such Holdings Ltd. v. The Queen, 96 DTC 6455, [1996] 3 CTC 221 (FCTD)-- summary under Subsection 31(1) Summary Under Tax Topics- Income Tax Act- Section 31- Subsection 31(1) The taxpayer, which also operated a building rental business, was found to have farming as its chief source of income given that its major preoccupation was its farming operation, and the losses initially suffered by the farming operation were start-up losses that could reasonably be expected. ...

Lagueux & Freres Inc., 74 DTC 6569, [1974] CTC 687 (FCTD)-- summary under Provincial Law Summary Under Tax Topics- Statutory Interpretation- Provincial Law In finding that lease agreements were in reality purchase agreements, Decary, J. stated: "fiscal law is an accessory system, which applies only to the effects produced by contracts. ...

Block Research & Development (1981) Corp. v. MNR, 87 DTC 5137, [1987] 1 CTC 253 (FCTD)-- summary under Subsection 223(1) Summary Under Tax Topics- Income Tax Act- Section 223- Subsection 223(1) "[T]he liability to pay tax under the Income Tax Act arises before any assessment has been made" and "under the Act, the Minister is entitled to assess at any time and is not bound to wait for the end of a fiscal year. ...