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 corporation then sold this middle lot to an individual purchaser coupled with a covenant that it would demolish this structure – which, however, it did not do until 45 days after closing. ...

The corporation then sold this middle lot to an individual purchaser couple with a covenant that it would demolish this structure – which, however, it did not do until 45 days after closing. ...

. … The argument put forward by Bowman that they are “nothings” for Canadian tax purposes because they are merely reputational payments arising in a non-business circumstance may ultimately be upheld by the Tax Court, but it is not so clear at this stage as to render the CRA’s position unreasonable. ...

. … Moreover, the Tribunals looked to the substantive matters rather than theoretical factors, such as causative link and governing law, and so applied a practical approach. ...

Agence du revenu du Québec, 2018 QCCQ 5692, aff'd 2020 QCCA 1496-- summary under Subsection 245(4) Summary Under Tax Topics- Income Tax Act- Section 245- Subsection 245(4) no abuse where individuals used PUC thrust upon them by an arm’s length investor (through PUC averaging) to subsequently strip surplus When the taxpayers’ corporation (“Opco”), a small business corporation, was in financial difficulty, a Quebec regional development fund agreed to inject equity capital in Opco on terms dictated by the fund – which entailed the fund investing in the common shares of Opco, so that the paid-up capital of the taxpayers’ shares was stepped-up from a nominal amount to $1.45 million (as a result of the aggregate class PUC being averaged on a per share basis). ...

The children … were declared as dependents of Mr. Rousseau for all the taxation years under litigation. ...

Agence du revenu du Québec, 2018 QCCQ 9487-- summary under Subsection 323(1) Summary Under Tax Topics- Excise Tax Act- Section 323- Subsection 323(1) assessment could be made of director for unremitted QST even though assessment therfor of dissolved corporation was void 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 five months later assessed Delia for the same amount under the Quebec equivalent of ETA s. 323(1) (and ITA s. 227.1(1).) ...

Before setting this order aside and directing that the Certificates of Appointmentbe be issued, Marrocco ACJ stated (at paras 34-35) that a will (which “is an instrument by which a person disposes of property upon death”) may “contain a trust, but this is not a requirement for a valid will” and quoted with approval (at para. 37) the statement in Williams on Wills that “Although the title to the assets vests in the personal representative … the property comprised in residue is not held in trust for the beneficiary under the will so as to invest any equitable interest in him.” ...

Such an interpretation goes against the purpose of the Act …. ...

In finding that the Customer Cash Contributions were ordinary income to the Distributors, Moshinsky J stated (at para. 165): As the Distributors’ businesses included connecting new customers to the electricity network, and as the Customer Cash Contributions were gains (in the sense that they were amounts derived) in respect of new connections, it follows that they constituted ordinary income …. ...