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Decision summary
Royal Bank of Canada v Commissioners for His Majesty's Revenue and Customs, [2023] EWCA Civ 695, aff'd [2025] UKSC 2 -- summary under Article 6
In concluding on this issue, she stated (at para. 97): … RBC does not hold, and indeed has never held, an interest in the Buchan field. ...
FCTD (summary)
3533158 Canada Inc. v. Canada (the Attorney General), 2024 FC 1090 -- summary under Paragraph 296(4)(b)
This registration-date issue was not resolved until over three months later, when CRA changed the effective date of the registration to August 1, 2012. 353 then refiled the returns for those earlier reporting periods during which it previously had not been registered, and on November 7, 2017, CRA assessed 353’s returns – but apparently not the initial three quarters. ...
Decision summary
Blank v. Commissioner of Taxation, [2015] FCAFC 154, aff'd [2016] HCA 42 -- summary under Paragraph 6(1)(a)
. … The applicant derived the first two instalments as income when, in January 2008, they were paid, with his agreement, to the FTA by GI on his behalf. ...
TCC (summary)
3295940 Canada Inc. v. The Queen, 2022 TCC 68, rev'd 2024 FCA 42 -- summary under Subsection 245(4)
The Queen, 2022 TCC 68, rev'd 2024 FCA 42-- summary under Subsection 245(4) Summary Under Tax Topics- Income Tax Act- Section 245- Subsection 245(4) circular use of capital dividends abused the purpose of the CDA Following preliminary transactions, on June 28, 2004, a Canadian holding company (“Micsau”) held all the shares, having a fair market value (“FMV”) and adjusted cost base (“ACB”) of $101.8M and $48.1M respectively, and a nominal paid-up capital (“PUC”), of a holding company (“3295940”), which held a minority shareholding (having an FMV of $88.5M and an ACB of $4M, reflecting the crystallization of the safe income on hand of such shares, and a nominal PUC) in another holding company (“Holdings” – which was majority-owned by an non-resident arm’s length investor), which carried on a Canadian generic-pharmaceuticals business. ...