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

At the same time, Budney requested the appellant to participate in a business corporation known as Affordable Tire & Auto Repair Ltd. ...

At 11 % interest, an increased expense of $6,600 is very close to the loss reported in each of the three years. ...

Appeals allowed. 1 At all relevant times, the Appellant was employed under contract by the province of On tario to assist in the production of various publications, etc. and appears to have worked at the offices of various Ministries. 2 A TD-1 form is generally provided to an employee by an employer to be completed for the purpose of providing the employee’s basic personal tax exemptions and other relevant infor mation to permit the employer to properly calculate the source deductions to be submitted to Revenue Canada. 3 Exhibit R-2. 4 ^he amounts referred to are those listed in the Appellant’s Exhibit A-4. 5 > Sheffield v. ...

. /?., [1998] 2 C.T.C. 2832 (T.C.C.), a decision of my colleague Bowman, at paragraph 18, in the factual background, he said:...Ms. ...

When the appellant and Musseau went into partnership it was under the name of W & M Company and business was carried on pursuant to a written partnership agreement. ...

It was pointed out that the 83 acres which he purchased of Lot 25 was not only in excess of what he wanted, but about 3 / times as large as Lot 20. ...

In support of such a position reference was made to several cases as follows: Southern v Borax Consolidated, Ltd, 23 TC 597; Algoma Central Railway v MNR, [1967] CTC 130; 67 DTC 5091; Toohey’s Ltd v Commissioner of Taxation (NSW), [1922] NSWSR 482; Kellogg Company of Canada Limited v MNR, [1942] CTC 51; 2 DTC 548; Hudson’s Bay Company v MNR, [1947] CTC 86; 3 DTC 968; Morgan v Tate & Lyle Ltd, 35 TC 406; Asamera Oil (Indonesia) Limited v Her Majesty the Queen, [1973] CTC 305; 73 DTC 5274; MNR v P P Drilling Ltd, [1976] CTC 58; 76 DTC 6028. ...

The legislation provided that, on the initiation of the taxation of capital gains, the market value of shares quoted on the London Stock Exchange be determined with reference to its market quotations on April 6, 1965, except where in consequence of special circumstances prices so quoted are by themselves not a proper measure of market value.” [1] In November 1964 serious discussions had begun between the chairman of Vickers Ltd and the taxpayer’s father, chairman of R W Crabtree & Sons Ltd contemplating the acquisition of all of the latter company’s issued shares by Vickers Ltd. ...

[Then follow alternative clauses as to property passing otherwise than by will] 8. (1) Subject as hereafter otherwise provided, duty shall be paid on all, property of a deceased that is situated, at the time of the death of the deceased, within the province. (2) Subject as hereafter otherwise provided, where property of a deceased was situated outside the province at the time of the death of a deceased and the successor to any of the property of the deceased was a resident at the time of the death of the deceased, duty shall be paid by the successor in respect of that property to which he is the successor. 2. (5) Where a corporation which is not resident in the province, other than a corporation without share capital, by reason of the death of a deceased acquires or becomes beneficially entitled to property of the deceased, (a) the corporation shall be deemed not to be the successor of the property except to the entent that the value of the shares of the shareholders of the corporation is not increased in value by the corporation acquiring or becoming beneficially entitled to the property; and (b) each of the shareholders of the ‘corporation shall be deemed to be a successor of property of the deceased to < the extent of the amount by which the value of his shares in the corporation is increased by. the corporation acquiring or becoming beneficially entitled to the property. ...

The Rosyth Building & Estates Co, Ltd v Rogers, 8 TC 11; 13. Mrs Anna H Martin v MNR (supra); 14. ...