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
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Decision summary
Rowe & Maw v. Customs and Excise Commissioners, [1975] 2 All E.R. 444 (Q.B.D.) -- summary under Section 178
Rowe & Maw v. Customs and Excise Commissioners, [1975] 2 All E.R. 444 (Q.B.D.)-- summary under Section 178 Summary Under Tax Topics- Excise Tax Act- Section 178 In finding that charges of a firm of solicitors for reimbursement of their railway and air fares constituted, on general principles, part of the consideration for the services provided by them to their clients, Bridge J. stated (p. 448): "On the one hand a solicitor (like any other agent) may purchase goods or services for its client, as for instance when paying stamp duty, court fees, or buying, say, a travel ticket to enable the client to travel. ...
Decision summary
Jenkin R. Lewis & Son Ltd. v. Kerman, [1970] 3 All ER 414 (CA) -- summary under Disposition
Lewis & Son Ltd. v. Kerman, [1970] 3 All ER 414 (CA)-- summary under Disposition Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Disposition S.24(2)(g) of the Agricultural Holdings Act 1948 (U.K.) gave a landlord of an agricultural holding, such as the plaintiff, the right to determine the tenancy within three months of the death of the tenant with whom the contract of tenancy was made. ...
Decision summary
Tael One Partners Limited v. Morgan Stanley & Co International PLC, [2015] UKSC 12 -- summary under Subsection 12(3)
Morgan Stanley & Co International PLC, [2015] UKSC 12-- summary under Subsection 12(3) Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(3) "accrue" describes the coming into being of a right or obligation Lord Reed stated (at para. 41): The word "accrue" is generally used to describe the coming into being of a right or an obligation (as, for example, in Aitken v South Hams District Council [1995] 1 AC 262), so that the person in question then has an accrued right, or is subject to an accrued liability, as the case may be. ...
Decision summary
Hague v. Cancer Relief & Research Institute, [1939] 4 DLR 191 (Man. K.B.) -- summary under Corporation
Cancer Relief & Research Institute, [1939] 4 DLR 191 (Man. K.B.)-- summary under Corporation Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Corporation corporation has separate legal personality In finding that an institute which section 2 of the Cancer Relief Act, 1930 (Manitoba) purported to make a "body corporate" was not, in fact, a corporation because there were no natural persons to compose or to constitute the corporation, Dysart J. stated (pp. 193-194): "What is a corporation? ...
Decision summary
CIR. v. Thomas Nelson & Sons, Ltd. (1938), 22 TC 176 (C.S. (1st Div'n)) -- summary under Paragraph 12(1)(c)
Thomas Nelson & Sons, Ltd. (1938), 22 TC 176 (C.S. (1st Div'n))-- summary under Paragraph 12(1)(c) Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(1)- Paragraph 12(1)(c) The taxpayer lent money to its Indian subsidiary under an agreement which provided that interest was to be paid at 3% per annum (a "remarkably low rate for an unsecured loan") and that on repayment of the principal (which would occur in 10 years time, or earlier on the occurrence of certain specified events or on the election of the subsidiary to repay) a premium would be paid whose amount was based on 2% per annum for the first two years during the term of the loan, and 2 1/2% per annum thereafter. ...
Decision summary
Lloyds & Scottish Finance Ltd. v. Cyril Lord Carpets Sales Ltd., [1992] B.C.L.C. 609 (HL) -- summary under Paragraph 20(1)(n)
Lloyds & Scottish Finance Ltd. v. Cyril Lord Carpets Sales Ltd., [1992] B.C.L.C. 609 (HL)-- summary under Paragraph 20(1)(n) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(n) A "block discounting" master agreement was found to establish that the taxpayer was assigning by way of sale to the respondent the amounts receivable by it under hire purchase contracts, rather than making assignments by way of charge, notwithstanding that in practice the arrangement worked in essentially the same manner as if the respondent were advancing to the appellant 80% of the receivables less the agreed discount. ...
Decision summary
The Queen v. Construction Bérou Inc. (formerly Fortin & Moreau Inc.), 98 DTC 6401 (FCTD), rev'd 99 DTC 5841 (FCA) -- summary under Depreciable Property
(formerly Fortin & Moreau Inc.), 98 DTC 6401 (FCTD), rev'd 99 DTC 5841 (FCA)-- summary under Depreciable Property Summary Under Tax Topics- Income Tax Act- Section 13- Subsection 13(21)- Depreciable Property The Quebec taxpayer leased various vehicles. ...
Decision summary
Lyall & Sons Construction Co. v. Baker, [1933] 2 DLR 264 (Ont CA) -- summary under Investment Contract
Lyall & Sons Construction Co. v. Baker, [1933] 2 DLR 264 (Ont CA)-- summary under Investment Contract Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(11)- Investment Contract The appellant demolition company had a contractual obligation to pay the respondent construction company for a demolitions project (in exchange for the right to salvage the wreckage), but the obligation only triggered when the respondent gave the appellant possession of the building to be demolished. ...
Decision summary
Edwards v. Bairstow & Harrison, (1955), 36 TC 207, [1955] UKHL TC (HL) -- summary under Machinery and Equipment
Bairstow & Harrison, (1955), 36 TC 207, [1955] UKHL TC (HL)-- summary under Machinery and Equipment Summary Under Tax Topics- Income Tax Act- Section 9- Capital Gain vs. ...
Decision summary
Versteegh Ltd & Ors v. Commissioners, [2013] UKFTT 642 (TC) -- summary under Subsection 15(1)
Versteegh Ltd & Ors v. Commissioners, [2013] UKFTT 642 (TC)-- summary under Subsection 15(1) Summary Under Tax Topics- Income Tax Act- Section 15- Subsection 15(1) required transfer of value between subs not a benefit One company in a group of UK companies (the "Lender") made a loan to a subsidiary (the "Borrower"). ...