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Line 25500 – Prescribed Zones – Alberta
Line 25500 – Prescribed Zones – Alberta Place names followed by numbers are Indian reserves. ... Alberta Table of the prescribed northern or intermediate zones for Alberta Zone A – Prescribed Northern Zones Zone B – Prescribed Intermediate Zones Place names followed by an asterisk "*" indicates that the location is in Wood Buffalo National Park. Adams Landing Amber River 211 Angus Tower * Assumption Beaver Ranch 163 Berdinskies Big Slough Bistcho Lake 213 Boyer Boyer 164 Boyer Settlement Buffalo Head Prairie Bushe River 207 Carcajou Carlson Landing Chateh Cherry Mountain * Child Lake 164A Chipewyan 201 Chipewyan 201A Chipewyan 201B Chipewyan 201C Chipewyan 201D Chipewyan 201E Chipewyan 201F Chipewyan 201G Davidson Lake * Embarras (Athabasca River) Embarras Portage Fifth Meridian Fitzgerald (Slave River) Footner Lake Forestry West Zama (airfield) Fort Chipewyan Fort Smith Settlement Fort Vermilion Fox Lake Fox Lake 162 Garden Creek Garden River (Pakwanutik River) Habay Hay Camp Hay Lake 209 High Level High Rock * Hutch Lake Indian Cabins Jackfish Jackfish Point 214 Jackfish River John D'Or Prairie John D'Or Prairie 215 Keg River Kemp River Kenny Woods La Crête Lambert Creek Tower Little Fishery Little Red River Lutose Margaret Lake Meander River Meander River Station Metis North Vermilion Settlement Old Fort Paddle Prairie Paddle Prairie Metis Settlement Parsons Lake * Peace Point Pine Lake * Point Brule Quatre Fourches Rainbow Imperial (airfield) Rainbow Lake Rocky Lane Slavey Creek Steen River Sweetgrass Landing Tall Cree 173 Tall Cree 173A Upper Hay River 212 Vermilion Chutes Wadlin Tower Warden Station * Wentzel Lake Zama Lake Zama Lake 210 Aggie Agnes Lake Albright Algar Amesbury Anzac Arcadia Assineau Assineau River 150F Atikameg Avenir Bad Heart Ballater Bay Tree Bear Canyon Beaverlodge Behan Belloy Berwyn Bezanson Bison Lake Bitumount Blueberry Mountain Bluesky Bonanza Braeburn Brainard Breynat Bridgeview Brownvale Buffalo Lake Cadotte Lake Calais Calling Lake Calling River Canyon Creek Chard Cheecham Cherry Point Chinook Valley Chipewyan Lake Clairmont Clarkson Valley Clear Hills Clear Hills 152C Clear Prairie Cleardale Clearwater 175 Codesa Conklin Cowper (airfield) Crooked Creek Culp Culp Station Deadwood Debolt Decrene Deer Hill Demmitt Devenish Dimsdale Dixonville Donnelly Draper Dreau Drift Pile River 150 Driftpile Duncan's 151A Dunvegan Eaglesham Early Gardens Elmworth Enilda Erin Lodge Eureka River Fairview Falher Faust Fawcett Lake Fitzsimmons Forest View Fort MacKay Fort McKay 174 Fort McMurray Freeman 150B Friedenstal Gage Gift Lake Gift Lake Metis Settlement Gilwood Girouxville Glen Leslie Goodfare Goodwin Gordondale Grande Prairie Gregoire Lake 176 Gregoire Lake 176A Gregoire Lake 176B Griffin Creek Grimshaw Grist Lake (airfield) Grouard Grouard Mission Grovedale Guy Halcourt Halcro 150C Harmon Valley Hawk Hills Hayfield Hazelmere Heart River Heart Valley Hermit Lake High Prairie Highland Park Hines Creek Hinton Trail Homestead Hondo Horse Lakes 152B Hotchkiss House River Indian Cemetery 178 Huallen Hythe Imperial Mills Janvier 194 Jean Baptiste Gambler 183 Jean Côté Joussard Judah Kathleen Kenzie Kinosis Kinuso Kleskun Hill Ksituan La Glace Lac Magloire Lake Saskatoon Last Lake Leddy Leicester Leighmore Leismer Lenarthur Lesser Slave Lake Settlement Little Buffalo Loon Lake Loon River Lothrop Lubicon Lake Lymburn Lynton Manir Manning Manning Station Margie Mariana Lake Marie-Reine Marie-Reine Station Marina Marten River McLennan Mildred Lake Mitsue Moose Portage Mount Valley Nampa Namur Lake 174B Namur River 174A New Fish Creek Niobe Normandville North Star Northmark Notikewin Overlea Pakashan 150D Peace Grove Peace River Peerless Lake Pelican Portage Peoria Philomena Pingle Pipestone Creek Pitlochrie Poplar Hill Poplar Ridge Prairie Echo Prestville Quigley Ranch Red Earth Creek Red Star Reno Rio Grande Roma Roma Junction Roxana Royce Rycroft St. ...
TCC (summary)
Bourgault v. The Queen, 2019 TCC 6 -- summary under Rectification & Rescission
The Queen, 2019 TCC 6-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission a rectification judgment was “justifiably obtained” and, therefore, followed for tax purposes On April 15, 2002, the taxpayer signed an agreement for the purchase of shares of a real estate corporation (“Quatre Saisons”) that stated that the purchase price was to be satisfied by the payment to the vendor (“Placeval,” a corporation owned by a Mr. ... Before granting the taxpayer’s appeal from the assessment, Favreau J stated (at paras. 55, 59-60, 62): [T]he judgment of the Superior Court is not binding on the respondent as neither the Attorney General of Canada nor the Minister was involved in the application. … Although the judgment of the Superior Court is not binding on the respondent and is not res judicata, the conduct of the parties, both before and after the concluding of the transaction, clearly demonstrates their true intention to purchase and sell the shares of Quatre Saisons for nominal consideration and not for consideration based on the future sales of lots. ... The financial statements of Quatre Saisons for its fiscal years ending on March 31 of 2003, 2004 and 2005, also reflected the commissions paid in the cost of the sales of the lots. … [I]t is evident that the agreement, as reduced to writing, contained drafting errors of material importance …. ...
Decision summary
Clark v HM Revenue and Customs, [2020] EWCA Civ 204 -- summary under Payment & Receipt
Clark v HM Revenue and Customs, [2020] EWCA Civ 204-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt there can be a payment even where there is a resulting trust in favour of the payor The taxpayer, a retired UK businessman, implemented a scheme to transfer funds (the “Suffolk Life Transfer") from his self-invested personal pension plan ("SIPP") to a second pension scheme (the “LML Pension,” of which the taxpayer was the sole member and whose named employer was a Cyprus company that entered into an employment contract with the taxpayer) in order to free up those funds for investment by him in the London residential property market. ... Unbeknownst to the participants, the LML Pension was void for uncertainty, as to which Henderson LJ stated (at para. 37): It is agreed … that the effect of the failure of the trusts of the LML Pension is that the transfer conveyed only bare legal title to the money, because an immediate resulting trust arose by operation of law. ... The money was intended to pass from the control and supervision of one registered pension scheme to another …. ...
Decision summary
Fairmont Hotels Inc. v. A.G. Canada, 2015 ONCA 441, aff'g 2014 ONSC 7302, leave granted, SCC docket 36606 -- summary under Rectification & Rescission
Canada, 2015 ONCA 441, aff'g 2014 ONSC 7302, leave granted, SCC docket 36606-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission continuing non-specific intention to maintain a tax neutral structure In order to facilitate the acquisition in 2002 of a hotel in Washington by a REIT ("Legacy") of which it was the manager, Fairmont Hotels Inc. ... " In dismissing the crown's appeal, Simmons JA stated (at paras. 10, 12): Juliar … does not require that the party seeking rectification must have determined the precise mechanics or means by which the party's settled intention to achieve a specific tax outcome would be realized. ...
Decision summary
Canada Life Insurance Company of Canada v. Canada (Attorney General), 2018 ONCA 562 -- summary under Rectification & Rescission
Canada (Attorney General), 2018 ONCA 562-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission a transaction resulting from a tax mistake should not be remedied under the Court’s general equitable jurisdiction A Canada Life subsidiary (CLICC) clearly intended to realize an accrued loss on its LP interest in a subsidiary partnership by winding it up. ... CLICC … does not ask the court to rescind the entire Transaction, and to restore it and its affiliates to their original rights, because to do so would not achieve its objective of triggering a loss to set off against its foreign exchange gains. ...
Decision summary
0741508 B.C. Ltd. and 0768723 B.C. Ltd. (Re), 2014 BCSC 1791 -- summary under Rectification & Rescission
(Re), 2014 BCSC 1791-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission failure to file timely tax returns did not invoke the dirty hands bar to equitable rescission In 2011, the petitioners conveyed undeveloped B.C. lands to a limited partnership with an affiliated general partner. ...
Decision summary
Re: Pallen Trust, 2014 DTC 5039 [at at 6726], 2014 BCSC 305, aff'd 2015 BCCA 222 -- summary under Rectification & Rescission
Re: Pallen Trust, 2014 DTC 5039 [at at 6726], 2014 BCSC 305, aff'd 2015 BCCA 222-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission rescission due to unexpected caselaw development An individual ("Pallen") or his spouse ("Tonn") settled the taxpayer, a family discretionary trust, and transferred his shares of "New Integrated" to a personal holding company ("Pallen Holdings") in exchange for shares under s. 85(1). ...
Decision summary
Stone's Jewellery Ltd. v. Arora, [2010] CTC 139, 2009 ABQB 656 (Alta QB) -- summary under Rectification & Rescission
Arora, [2010] CTC 139, 2009 ABQB 656 (Alta QB)-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission A corporation ("Stone's") had entered into an agreement in 1996 to purchase lands for $500,000. ...
Decision summary
Kaleidescape Inc. v. MNR, 2014 ONSC 4983 -- summary under Rectification & Rescission
MNR, 2014 ONSC 4983-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission clarification that directions to a trustee shareholder were to be made by the mooted CCPC's board rather than a non-resident executive The applicant ("K-Can") was intended to qualify as a Canadian-controlled private corporation. ...
Decision summary
Canada Life Insurance Co. of Canada v. A.G of Canada, 2015 DTC 5128 [at at 6378], 2015 ONSC 281, rev'd 2018 ONCA 562 -- summary under Rectification & Rescission
A.G of Canada, 2015 DTC 5128 [at at 6378], 2015 ONSC 281, rev'd 2018 ONCA 562-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission rectification transactions to avoid s. 98(5) rollover contained 2 more transactions than in original plan In order that the applicant ("CLICC") could realize an accrued capital loss on its 99% limited partner interest in a subsidiary limited partnership ("MAM LP") (and following preliminary dividends): On December 7, 2007, MAM LP distributed an asset to CLICC and a wholly-owned subsidiary of CLICC ("CLICC GP") based on their respective 99% and 1% interests. ...