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

Before finding that the taxpayer continued to reside in Quebec for his 2009 and 2010 taxation years, Pokomàndy JCQ stated (at paras. 69-70, TaxInterpretations translation): The Court is convinced … that since 2011 this project of going to work in Ontario in order to perfect his English has become a life project that materialized with the residence transfer to this location. ...

Similarly, in the second (dismantling) case (paras. 57, 59: [T]he value of the performance of dismantling and waste disposal … must be regarded as equal to the amount that the purchaser, that is a demolition company, takes into account as a factor reducing the purchase price of the goods to be dismantled. ...

After noting that the description of the legal services provided had not been revealed to the ARQ on the grounds of privilege, Chalilfour JCQ stated (at paras. 133-135, TaxInterpretations translation): Not waiving professional privilege could certainly render the reversing of the presumption of validity of an assessment … more difficult. ...

In fact, the quality of the sound recording had everything to do with the quality of the physical medium …. ...

If the alleged fault of the respondents rested solely on the erroneous collection of taxes on products sold, it could be concluded that the recourse sought attempted to circumvent the ETA and STA …. ...

A customer pays for parking in a car park of the appellant (NCP) by going to the ticket machine which, on its tariff board, displays a price for one hour of £1.40 – but also states that change is not given but overpayments are accepted. ...

. … In sum, I am of the view that the debt claim bequeathed to the Taxpayer was transferred to her on November, 12, 2008, being the date of death of Mr. ...

. … [N]o transformation or modification of much significance was made to the Triplex in order for the three units to be linked in some manner to each other. ...

He stated (at para. 64, TaxInterpretations translation): [T]he simple fact of wishing to obtain a better price on the sale of the immovable is insufficient for concluding that a taxpayer was engaged in an adventure or concern in the nature of trade; a taxpayer engaging in a project carrying risk or having a commercial character is not necessarily carrying on a business …. ...

Whether the property was a “former business property” turned on whether (under the definition thereof) it qualified as a “property … leased by the taxpayer to a person related to the taxpayer and used by that related person principally for any other purpose.” ...