Search - 哈尔滨到北京 公里数

The appeal raises the question of the liability of the appellant to pay Canadian income tax in respect of income derived by him as a partner from activities carried on in the United States by certain partnerships organized in the United States, in view of the provisions of the Convention and Protocol between Canada and the United States for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion in the Case of Income Taxes and of The Canada-United States of America Tax Convention Act, 1943, S. of C. 1943-4, c. 20 (as amended by $. of C. 1950, c. 27), by which the Convention and Protocol were approved and declared to have the force of law in Canada and to prevail over any other law to the extent of any inconsistency therewith. ...

This regulation provides for a depletion allowance of 3314 % of ‘‘the aggregate of... profits for the taxation year reasonably attributable to the production of... industrial minerals... minus the aggregate amount of deduction provided by...’’ ...

By his Notice of Assessment dated January 10, 1952, the appellant disallowed the payment of $4,000.00 as ‘‘ Alimony Disallowed, $4,000.00” and endorsed on the back of the said notice were the words “Lump Sum Payments of alimony not an allowable Expense’’. ...

The appellant’s hotel, hereinafter referred to as the ‘‘ Forbes’ Hotel,’’ is located at Shuter and Mutual Streets in the City of Toronto. ...

For the taxation year 1948 the following provisions enacted by Section 16, subsection 4 of c. 63 of the Statutes of Canada, 1947, were in effect: "‘A corporation whose chief business is that of mining or exploring for minerals is entitled to deduct from income, as defined in the said Act, of the year of expenditure, an amount equal to all prospecting, exploration and development expenses incurred by it in searching for minerals during the year 1948 if the corporation files certified statements of such expenditures and satisfies the Minister that it has been actively engaged in prospecting and exploring for minerals by means of qualified persons and has incurred the expenditure for such purposes. ’’ For the year 1947, Section 8, subsection 9, of the Income War Tax Act provided as follows: "A corporation whose chief business is that of mining or exploring for minerals is entitled to deduct from the aggregate of the taxes under this Act and the Excess Profits Tax Act, 1940, payable by it in respect of the year of expenditure, twenty percentum of all prospecting, exploration and development expenses incurred by it in searching for minerals during the year 1947; provided that no such deduction shall be allowed unless the corporation files certified statements of expenditures and satisfies the Minister that it has been actively engaged in prospecting and exploring in Canada for minerals by means of qualified persons and has incurred the said expenditures for such purposes.” ...

Woodifield (1906) A.C. 448, at p. 452; 5 T.C. 215, at p. 219; Clerical, Medical & General Life Ass. ...

.), undertook, among other things, for a period of 97 years, to work, manage and operate the system of telegraph of the defendant company with the right to use and occupy all the offices, stations, buildings and property of the company, save and except the board room, with the adjacent secretary’s room and part of vault; and furthermore the contractors bound and obliged “ (6) themselves to pay all costs and expenses of operation of every description, including municipal taxes and assessments in the property owned by the company, etc.” ...

& P. Main Sewerage Board v. Bensted [1907] A.C. 264. No one can be held to make a profit or gain by dealing with himself only; two parties are needed, and under the pool scheme, the associations being the agent of the farmer, they are one and the same. ...

Every purchaser of a berth in a sleeping car or of other sleeping accommodation on a railway train shall pay to the person selling the berth or other sleeping accommodation for the Consolidated Revenue Fund in addition to the price paid therefor, a sum equal to ten per cent of the said price, provided that in no ease shall the tax imposed by this subsection be less than twenty-five cents/ ‘ The controversy here relates to these two taxes. ...

(to be referred to hereafter as ‘‘ Rice Mills’’), as sales tax, under the provisions of The Special War Revenue Act, the sum of $9,741.55, which with penalty interest amounted to $11,004.87, on November 30, 1936. ...