Search - 包建铎违纪违法案件以案促改以案促治专题组织生活会 个人对照检查

(the “Canadian Resort Point Purchasers” and “American Resort Point Purchasers,” respectively – who also thereupon became member of the Appellant, along with the Canadian and U.S. ...

. … [I]t follows from the case-law...that if the supply price is lower than the cost price, the deduction cannot be limited in proportion to the difference between the supply price and the cost price, even if the supply price is considerably lower than the cost price, unless it is purely symbolic…. ...

. … …The Applicant chose to collect revenue generated by the machines personally, rather than through his corporation, and he cannot rely upon an accounting principle to ignore the legal reality of the lease and argue that the cost of the lease payments should be attributed to him personally and deductible from his personal income for the 2001 taxation year. …... ...

. … [T]he Appellant, when selling its limited partnership interests in Atria LP and CEC LP to the subsidiaries of AIMCo, clearly took into account the transactions… that resulted in the packaging of the real property into limited partnerships and the bumping of the adjusted cost base with respect to such limited partnerships. ...

. … Parliament…made the positive decision to limit the application of subsection 69(11) to transfers to tax-exempt entities that occur within the three-year period [in s. 69(11).] ...

…[T]he authorities … must also take account of the additional information provided by the taxable person. ...

. … That a person may not be aware at an earlier point in time what the criteria of liability may subsequently be made to apply to that earlier point in time does not make the legislation arbitrary or incontestable…. ...

. … Also paragraph 191.1(2)(c) of the ETA is a condition that, if satisfied, will result in certain consequences under the ETA. ...

. … The [wife and children] acquired the shares from the Appellant for a purchase price of $0.01 per share and immediately thereafter sold them for a cash purchase price of $8,645 per share. ...

Finally, Smith J found (at para 58): As indicated… in Kyte … there may be discrepancies as the amounts owed for source deductions may be fluid. ...