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 information laid before the issuing judge had not addressed any absence of an alternative solution – and Hilton JCA also chided the ARQ for failure to disclose the “material fact” that the law firm in question was acting for the client in the tax dispute with the ARQ. ...

. … Although Mr. RF works in the construction industry, this does not deprive him of the right to acquire and sell his principal residence if circumstances make it unavoidable or desirable, even if the transactions occur over a relatively short period of time. ...

. … The provision by the customer of the loan was the consideration for both the payment of interest and the provision of the banking services. ...

. … As I construe subsection 84(3), a corporation is deemed to have paid a dividend at the time of the acquisition of its shares and, even if the consideration for the shares acquired is payable over a considerable period of time, it must, for the purposes of income tax law, be regarded as being payable at the time of the acquisition. ...

Agence du revenu du Québec, 2018 QCCQ 9487-- summary under Subsection 296(1) Summary Under Tax Topics- Excise Tax Act- Section 296- Subsection 296(1) QBCA did not provide that audit or other proceedings could be commenced against a dissolved corporation The ARQ commenced a QST audit of a corporation (Motostar) after its voluntary dissolution by its sole individual shareholder (Delia) and assessed Motostar for some unremitted QST – and then assessed Delia for the same amount under the Quebec equivalent of ETA s. 323(1) (and ITA s. 227.1(1).) ...

. … Irrespective of the applicable section of the Copyright Act, it is clear that Appellant was assessing the purchase of rights. ...

(k.1) In finding that the recurring costs of racks and boxes incurred by an exploration company in order to store core samples were capital expenditures, Fournier J stated (at para. 295, TaxInterpretations translation): The core boxes and racks allowed for the permanent preservation of a duplicate of each sample taken during exploration …. ...

In finding that these distributions did not entail the taxpayer giving consideration to the trust for s. 160 purposes, Gagnon J found that: “the trustee's distributions had no impact on the rights of a beneficiary of the Trust who had or had not received a distribution” (para. 65, TaxInterpetations translation); and although the taxpayer “had a right under the Trust to be considered by the trustee for any distribution on the same basis as the other beneficiaries … there is no reason to believe that anyone would have paid even a very small amount for [this right]” and “[i]n fact, it is highly unlikely that such a right could be transferred to a third party” (para. 67). ...

ARQ, 2025 QCCQ 1330-- summary under Subsection 152(1) Summary Under Tax Topics- Income Tax Act- Section 152- Subsection 152(1) a CBCA corporation can be assessed within 2 years of its dissolution – or thereafter, if revived by the ARQ or CRA The ARQ assessed the taxpayer within two years of the taxpayer’s dissolution pursuant to s. 210(3) of the CBCA. ...

In concurring in a reversal of a finding of the full Federal Court that the "dominant purpose" of the taxpayer for purposes of Part IV of the Income Tax Assessment Act of 1936 was to obtain the maximum return on money invested after the payment of all applicable costs including tax, and not to obtain a tax benefit, McHugh J. stated: "... ...