Search - 哈尔滨到北京 公里数

Cassels Brock & Blackwell LLP, 2013 ONCA 165, rev'g 2012 DTC 5013 [at 6604], 2011 ONSC 6724-- summary under Negligence, Fiduciary Duty and Fault Summary Under Tax Topics- General Concepts- Negligence, Fiduciary Duty and Fault potential problem did not engage limitations period The plaintiff, along with about 900 other taxpayers, indirectly acquired rights to timeshare weeks at a Carribean resort, and donated the rights to a Canadian athletic association along with enough cash to discharge encumbrances on the timeshare weeks. ... The limitations period could not commence until the claim was discoverable, and a mere " potential problem" does not make a claim discoverable. ...

Revenue Commissioners v Susquehanna International Group Ltd & ors, [2025] IECA 123-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 a US LLC was not a resident of the US for purposes of the US-Ireland treaty The taxpayers were Irish resident companies, which were part of a group whose ultimate parent was a single member LLC (“SIH LLC”), which was fiscally transparent for U.S. tax purposes. ... " Allen JA stated (at para. 42) that, as “the purpose of the treaty is to avoid double taxation … it stands to reason that it should only apply to persons who otherwise would be exposed to a liability to pay tax. ...

Eastwood & Co. v. MNR, 94 DTC 6411 (BCSC)-- summary under Solicitor-Client Privilege Summary Under Tax Topics- General Concepts- Solicitor-Client Privilege Documents in the nature of simple reports by a conveyance agent relating to certain noted conveyancing matters were not privileged. ...

AFS & Co. Limited Partnership No. 5 v. The Queen, 2001 DTC 5330 (FCTD)-- summary under Solicitor-Client Privilege Summary Under Tax Topics- General Concepts- Solicitor-Client Privilege General discussion of the privilege before finding that specific documents were privileged. ...

In re James Richardson & Sons, Ltd., 82 DTC 6211 (FCA)-- summary under Section 231.2 Summary Under Tax Topics- Income Tax Act- Section 231.2 The issuance of a S.231(3) requirement is not a decision that may be appealed under S.28 of the Federal Court Act. ...

Firestone Tyre & Rubber Co. Ltd. v. Lewellin (1957), 37 TC 111 (HL)-- summary under Agency Summary Under Tax Topics- Income Tax Act- Section 9- Agency- Agency The Court affirmed a finding that sales by the taxpayer, which was a U.K. special-purpose manufacturing subsidiary of a U.S. corporation, were made by it as agent for the U.S. corporation. ...

APL Oil & Gas Ltd. v. The Queen, 96 DTC 1666 (TCC)-- summary under Subsection 152(8) Summary Under Tax Topics- Income Tax Act- Section 152- Subsection 152(8) incorrect year referenced An assessment that erroneously referred to the taxation year of the taxpayers ending on January 2, 1987 rather than December 31, 1986 was deemed to be valid under s. 152(8). ...

Patons & Baldwins Ltd. v. MNR, 69 DTC 189, [1969] Tax A.B.C. 221-- summary under Subsection 147.2(1) Summary Under Tax Topics- Income Tax Act- Section 147.2- Subsection 147.2(1) S.11(1)(g) of the pre-1972 Act was found to preclude the deduction of annual contributions to an unregistered pension plan under the general law relating to deductions by commercial enterprises. ...

Canada and Coopers & Lybrand Ltd., 86 DTC 6243 (BCSC)-- summary under Subsection 227(9) Summary Under Tax Topics- Income Tax Act- Section 227- Subsection 227(9) A penalty for failure to remit employee source deductions on the due date of February 15, 1985 was not a claim provable in bankruptcy because the proposal under the Bankruptcy Act was filed on February 6, 1985. ...

Lowe & Ors. v. C.I.R. (New Zealand), [1984] BTC 3 (PC)-- summary under Subsection 10(1) Summary Under Tax Topics- Income Tax Act- Section 10- Subsection 10(1) The taxpayers argued unsuccessfully that since "historic cost accounting was unfair", their profit from the sale of land inventory should be reduced to reflect inflation. ...