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

In summarizing this arrangement, Hogue, J.C.A. stated (at para. 42, TaxInterpretations translation): … [T]he agreed formula means that PCI must repay the advances received over 15 years if its revenues are stable. ...

The open court principle allows any person to inspect a court record and any annex "that is available to the public" …. ...

Monaghan J stated (at para. 213): … The Tax Court will address all challenges to the correctness of the assessment made after the transfer pricing provisions have been applied, including whether the conditions for their application are met, the amount of any adjustments, the liability for penalties and whether the Minister exercised her discretion properly. ...

Harris filing returns showing employment and dividend income from 405 Canada – and although those returns were filed after 405 Canada’s VDP application, “[i[t would be incongruous” for the 405 Canada disclosure to be rendered voluntary “simply because a related taxpayer did not file the returns that would reveal the same information until after filing a VDP application” (para. 19). the possibility mentioned by CRA in its enforcement letter of arbitrarily assessing Mr. ...

Smith J indicated (at para. 522) that: [T]he T3GR Return was the prescribed form intended by CRA to meet the filing requirements of RRSP trustees pursuant to paragraph 150(1)(c) and subsection 207.2(1) of the Act and section 204 of the Regulations and … it was intended as a streamlined process for the reporting of group RRSPs involving hundreds of thousands of plans under one specimen plan. ...

The ARQ reassessed to deny the deduction by Mobile of legal and accounting fees incurred by it in investigating the disappearance of the sales proceeds and in relation to the Superior Court action, primarily on the basis that they were capital expenditures (TA, s. 129, similar to ITA s. 18(1)(b) – although TA s. 128, similar to ITA s. 18(1)(a), was also invoked). ...

The information is required to verify the compliance of the taxpayer being audited and no application for judicial authorization is required …. ...

. … They are an exchange device because they may be used as consideration for property or services in the same way as money or a gift certificate. ...

. … 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. ...