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Decision summary
Agence du revenu du Québec v. 102751 Canada Inc., 2021 QCCA 605 -- summary under Legal and other Professional Fees
The ARQ reassessed to deny the deduction by Mobile of legal and accounting fees incurred by it in investigating the disappearance of the sales proceeds and in relation to the Superior Court action, primarily on the basis that they were capital expenditures (TA, s. 129, similar to ITA s. 18(1)(b) – although TA s. 128, similar to ITA s. 18(1)(a), was also invoked). ...
FCTD (summary)
Zeifmans LLP v. Canada (National Revenue), 2021 FC 363, aff'd 2022 FCA 160 -- summary under Subsection 231.2(1)
The information is required to verify the compliance of the taxpayer being audited and no application for judicial authorization is required …. ...
FCA (summary)
Canadian Imperial Bank of Commerce v. Canada, 2021 FCA 96 -- summary under Section 181.2
. … They are an exchange device because they may be used as consideration for property or services in the same way as money or a gift certificate. ...
Decision summary
Dupuis v. Agence du revenu du Québec, 2021 QCCA 1061 -- summary under Subsection 165(3)
. … The time limits for the assessment and collection of the tax debt are all expressly provided for in the TA and the TAA. ...
TCC (summary)
Wenikajtys (Estate) v. The Queen, 2021 TCC 93 (Informal Procedure) -- summary under Paragraph (a)
. … If the Minister agrees with Mr. Turski, and indeed with me, that the application of the 36-month rule in this case seems to lead to an unfair and unreasonable result, and that the public interest that led to the adoption of that rule does not apply in this case- and I hope the Minister will so agree- then the Minister will ask Cabinet to approve the remission order. ...
TCC (summary)
Canadian Imperial Bank of Commerce v. The Queen, 2022 TCC 26, aff'd 2023 FCA 195 -- summary under Res Judicata
. … I [also] do not believe it is in the public interest that I decide on an issue without hearing evidence that is relevant to the determination as to whether or not the exclusions apply. ...
Decision summary
Agence du revenu du Québec v. Assurances générales Desjardins Inc., 2022 QCCA 57 -- summary under Paragraph A(a)
. … Regarding the IPT, section 527 of the QSTA clearly provides that the insurer, in its capacity as agent, must account for the tax collected in the preceding calendar month at the end of the month. ...
TCC (summary)
President's Choice Bank v. The Queen, 2022 TCC 84, rev'd 2024 FCA 135 -- summary under Subsection 181(5)
. … There is a direct link between the PCB Points that are issued in conjunction with an exempt financial service supplied by PC Bank to Cardholders and an expense that is paid when the PCB Points are redeemed by Cardholders. ...
TCC (summary)
Gestion M.-A. Roy Inc. v. The King, 2022 TCC 144, aff'd 2024 CAF 16 -- summary under Subsection 15(1)
. … In this case, the appellants could revoke the designation of R3D as beneficiary at any time, but this is a right that flows from the insurance contract. ...
Decision summary
Agence du revenu du Québec v. FTI Consulting Canada Inc., 2022 QCCA 1740 -- summary under Subsection 32(7)
. … In also finding that the Court below had not erred in declining to exercise its residual discretion to permit the ITC claims (viewed as a post-filing claim) against the tax owing, he stated (at para. 48) that this would have been “inconsistent with the remedial objectives of the CCAA, regardless of whether the focus is on restructuring the debtor’s affairs or on liquidation.” ...