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Decision summary
Latulippe v. Agence du revenu du Québec, 2019 QCCA 2177 -- summary under Paragraph 45(1)(a)
He stated (at para. 64, TaxInterpretations translation): [T]he simple fact of wishing to obtain a better price on the sale of the immovable is insufficient for concluding that a taxpayer was engaged in an adventure or concern in the nature of trade; a taxpayer engaging in a project carrying risk or having a commercial character is not necessarily carrying on a business …. ...
Decision summary
Gestions Calce Ltée v. Agence du revenu du Québec, 2019 QCCQ 7377 -- summary under Former Business Property
Whether the property was a “former business property” turned on whether (under the definition thereof) it qualified as a “property … leased by the taxpayer to a person related to the taxpayer and used by that related person principally for any other purpose.” ...
Decision summary
Dare Human Resources Corporation v. Ontario (Revenue), 2019 ONCA 549 -- summary under Employer
The appeal judge did not … fail to consider any relevant factor. ...
Decision summary
BT Céramiques Inc. v. Agence du revenu du Québec, 2020 QCCA 402 -- summary under Subsection 24(1)
. … [It] simply could not take advantage of the proceeds of the illegally obtained warrants. ...
Decision summary
Ferme Lunick Inc. v. Agence du revenu du Québec, 2020 QCCQ 1703 -- summary under Paragraph (a)
. … The Agricultural Activities are not carried on independently of the Manufacturing and Processing Activities given Lunick Farm's strategy of vertical integration. ...
Decision summary
Immeubles Zamora ltée v. Agence du revenu du Québec, 2020 QCCA 894 -- summary under Real Estate
In dismissing their appeal, Bouchard JCA indicated that the fact that this was an isolated transaction and that they were not “flippers” was not decisive, the judge had not erred in noting the complete absence of any business plan or other documentary proof of their lack of motivating intention to sell (although, he noted, at para. 34, TaxInterpretations translation, and before referring to Hickman Motors in this regard) that “it is true that there are exceptional situations where the taxpayer manages to demolish the ARQ's assumptions of fact despite the taxpayer’s evidence being limited to the taxpayer’s testimony”) and (at para. 44) that “the judge did not commit a reviewable error … by holding that the appellants had a secondary intention to divest themselves of their project in the event of an interesting offer being made to them.” ...
Decision summary
Agence du revenu du Québec v. Des Groseillers, 2021 QCCA 906, aff'd 2022 SCC 42 -- summary under Paragraph 7(3)(a)
. … While section 54 ensures that stock option benefits are subject to sections 49 et seq. of the T.A. and excludes them from the scope of sections 36 and 37 [equivalent to ITA ss. 5, 6], it is not, in the absence of clear legislative indications to that effect, a code so complete and airtight that the application of section 422 is excluded. ...
Decision summary
Agence du revenu du Québec v. Cristofaro, 2021 QCCA 1025 -- summary under Section 118.9
Before confirming the ARQ view (and reversing the decision below), the Court noted that the daughter was not subject to Quebec income tax, referred to the Oceanspan decision as being “particularly illuminating” (para. 44, TaxInterpretations translation), and further stated (at para. 45): The Oceanspan decision was recently cited … in the Marino decision. ...
Decision summary
Pavages Vaudreuil Ltée v. Agence du revenu du Québec, 2021 QCCQ 3890 -- summary under Paragraph 1104(9)(e)
(c) exclusion also did not apply, Bourgeois JCQ stated (at para. 44, TaxInterpretations translation): The acquired goods were used exclusively for the handling of materials already collected by the cable excavator, in the context of operations necessary for washing, sorting and crushing and then stacking the various products intended either to be sold to third parties (as to 73.3%) or to be used by the plaintiff (as to 26.67%) …. ...
Decision summary
Nadeau v. Agence du revenu du Québec, 2021 QCCQ 4638 -- summary under Retiring Allowance
. … The ARQ correctly argues that it is undisputed in several respects that the award in question was intended to compensate the plaintiffs for an injury directly resulting from the loss of their employment. ...