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

Davis stated (at p. 697): "... the section taken as a whole, which, in my opinion, is the way in which it must be interpreted, is intended to apply to persons who fall to be taxed or otherwise dealt with under the provisions of the Canadian Income Tax Act and who report to the Canadian Government the income arising from the operation of the business or businesses whose sale is the central concern of the said section 85D. ...

" … The fact that the limited partners may have had an ownership interest in the assets did not detract from the conclusion that the General Partner was a "purchaser" within the meaning of the Tax Act and was required to pay tax on the full amount of the purchase price allocated to the tangible personal property. ...

Although the U.S. dollars delivered under the contract appreciated significantly, Sir John Vinelott found (at p. 137) that: "... the agreement between the company and the bank was a single composite agreement under which the company could not deal with the forward contract without the consent of the bank and under which the bank was to be at liberty to use the dollars purchased in discharge of the dollar loan, to the extent that that had not been repaid before 15 March 1983. ...

Repairs or Running Expense pension fund settlement was one-time expenditure for enduring benefit In finding that a lump sum paid by the taxpayer to establish a pension fund for the benefit of its employees was a non-deductible capital expenditure, Viscount Cave L.C. stated (pp. 213-214): "... ...

…[A]ll the three contracts are for three different purposes – for charter of accommodation barge, for use of barge in domestic are [sic] and for replacement decks. ...

" See summary under General Concepts – Rectification and Rescission. ...

" See summary under Treaties – Art. 9. ...

With respect to the initial character of each overriding commissions as income when receivable, Brandeis J. stated (p. 199): "... the mere fact that some portion of it might have to be refunded in some future year in the event of cancellation or reinsurance did not affect its quality as income... ...

Especially must this be so where the chattels being considered are subject to wear and tear through use … In my opinion the word “permanent”, as used by King J. should be interpreted for the purposes of this appeal as indicating the object of having the carpeting remain where it is so long as it serves its purpose. ...

. … It is provided that in such a case, by virtue of the dissolution of a business corporation, its rights and obligations become those of its sole shareholder, which becomes a party to any judicial or administrative proceeding to which the dissolved corporation was a party. ...