Search - 哈尔滨到北京 公里数

Canada (Attorney General), 2012 NSSC 217-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission proposed rectification inconsistent with financial statements The applicant, incorporated by a U.S. corporation ("Fidelity National"), received $23,659,000 from Fidelity National in order to finance its business in Nova Scotia. ...

Canada (Attorney General), 2009 CanLII 18234 (Ont SC)-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission unopposed application to reduce capital dividend to CDA balance The directors of the taxpayer mistakenly declared a dividend in an amount exceeding its capital dividend account, and it elected under s. 83(2) to treat it as capital dividend. ...

Canada, 2023 QCCS 3510, rev'd 2025 QCCA 134-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission transaction documents rectified because they did not implement the parties' intention to not trigger Part IV tax Four individuals held their indirect holdings of 10%, 10%, 5% and 5% of the common shares of a Canadian-controlled private corporation (Structures) through three holding companies (the "Holdcos"). ...

Samarkand Film Partnership No. 3 & Ors v Revenue and Customs, [2017] EWCA Civ 77-- summary under Business Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Business non-trading business At issue was whether two partnerships which acquired interests in films and immediately leased their acquired interest for fixed, increasing, secured and guaranteed rental payments for a 15 year period, and were acknowledged to have a business, were carrying on a trade. ... " In affirming the finding below (initially made by the First-Tier Tribunal) that the partnerships were not carrying on a trade, Arden LJ stated (at paras 59, 61, 66): … [I]t is now clear from Eclipse … that the question whether what the taxpayer actually did constitutes a trade has to be answered by standing back and looking at the whole picture…. … The [FTT’s] overall assessment of the commercial nature of the agreements as the payment of a lump sum in return for a series of fixed payments over 15 years…was not a crude conclusion based on an impermissible transformation of the taxpayers' activities into an economic equivalent, but rather a way of expressing the ultimate inference of fact which they drew from the totality of the primary facts which they had found. ...