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FCA (summary)

McNeeley v. Canada, 2021 FCA 218 -- summary under Regulation 4800.1

In finding that it was an EBP, he cited (at para. 29) Oldman for the proposition that “[o]rdinarily an Act of Parliament must prevail over inconsistent or conflicting subordinate legislation,” and then stated (at para. 30): [S]ince the definition of a prescribed trust is set out in the Regulations, the paramountcy of the definition of an employee benefit plan in the Act must govern. ...
FCA (summary)

Cliff v. Canada, 2022 FCA 16 -- summary under Subsection 227.1(4)

Furthermore, the secretary of her husband’s accountant prepared a “Form 1 Initial Return/Notice of Change” stating that the taxpayer’s directorship started on September 4, 2003 and ceased on December 12, 2003, although the accountant’s recollection of it having been sent to the Ontario Ministry of Consumer and Commercial Relations, was not reflected in the Ministry’s records. ...
FCTD (summary)

Canada (National Revenue) v. Ghermezian, 2022 FC 236, aff'd in part 2023 FCA 183 -- summary under Subsection 231.1(1)

However, Southcott J accepted the taxpayers’ submissions in this regard by concluding (at para. 111) that “s 231.1 does not authorize issuance of a demand compelling the recipient to provide, through written answers to questions, substantive information relevant to a taxpayer’s tax position” as contrasted to “authoriz[ing] compulsion of only pre-existing documentation” (para. 79). ...
FCTD (summary)

Canada (National Revenue) v. Ghermezian, 2022 FC 236, aff'd in part 2023 FCA 183 -- summary under Subsection 231.2(1)

., Branigan, 2004 FC 245)] …. Southcott J found however that the somewhat detailed affidavit evidence of a CRA manager was sufficient to meet the burden on the Minister to establish service of the s. 231.2(1) requirements, even though the requirements of s. 244(5) had not been met. ...
Decision summary

Commissioner of Taxation v PricewaterhouseCoopers , [2022] FCA 278 -- summary under Solicitor-Client Privilege

. It is therefore necessary to consider, on a document-by-document basis, whether each Sample Document is subject to legal professional privilege. ...
FCA (summary)

Kufsky v. Canada, 2022 FCA 66 -- summary under Estoppel

Webb JA found that the taxpayer was estopped from now arguing that the amounts that she had treated as dividends in fact were not dividends (so that s. 160 did not apply to their payment)- because the appropriate procedures for the declaration and payment of the amounts as dividends were not followed and because s. 38(3) of the OBCA prohibited the payment of a dividend by an insolvent corporation on the basis of the application of the principle (based on Wolofsky, 2001 FCA 119) that: [A] taxpayer who has benefited from having an amount included in his or her income as a dividend in a particular taxation year (and who has not objected to the assessment of tax based on having received this dividend) is estopped from claiming in any subsequent appeal related to the application of section 160 of the Act, that the previous filing position was wrong. ...
FCA (summary)

Kufsky v. Canada, 2022 FCA 66 -- summary under Illegality

Webb JA found that the taxpayer was estopped from now arguing that the amounts that she had treated as dividends in fact were not dividends (so that s. 160 did not apply to their payment)- because the appropriate procedures for the declaration and payment of the amounts as dividends were not followed and because s. 38(3) of the OBCA prohibited the payment of a dividend by an insolvent corporation on the basis of the application of the principle that: [A] taxpayer who has benefited from having an amount included in his or her income as a dividend in a particular taxation year (and who has not objected to the assessment of tax based on having received this dividend) is estopped from claiming in any subsequent appeal related to the application of section 160 of the Act, that the previous filing position was wrong. ...
FCA (summary)

Canada v. Dow Chemical Canada ULC, 2022 FCA 70, leave granted 23 February 2023 -- summary under Section 18.5

Since section 18.5 of the Federal Courts Act only excludes the Federal Court from reviewing a decision when another Act expressly provides a right of appeal, this determination would lead to the finding that section 18.5 is not a bar to the Federal Court judicially reviewing this decision of the Minister. ...
Decision summary

CS Communication v. Agence du revenu du Québec, 2022 QCCQ 1175 -- summary under Paragraph (a)

Agence du revenu du Québec, 2022 QCCQ 1175-- summary under Paragraph (a) Summary Under Tax Topics- Income Tax Act- Section 127- Subsection 127(9)- Contract Payment- Paragraph (a) expenditures under an agreement to develop software for a 3rd party pursuant to its specifications were not associated with contract payments The taxpayer (“CS Canada”), which carried on a business of developing software for use in the aeronautics industry, entered into a “long term purchase agreement” with a third party (“Pratt & Whitney” or “P&W”) for the sale to it of control system software. ...
TCC (summary)

Stroud v. The Queen, 2022 TCC 86 (Informal Procedure) -- summary under Commercial Activity

Spiro J stated (at para. 34): Having applied the criteria in Moldowan, I find that each factor (other than time spent), weighs heavily in favour of the conclusion that the Appellant did not carry on his farm business with a reasonable expectation of profit. ...

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