Search - 屯门 安南都护府

.* [3] I have also reproduced by way of footnote Section 3(5) (a) [4] t which sets forth the badges of ‘ ownership ” of a policy of insurance for the purposes of Section 3(1)(m). ... For these reasons the appeal is allowed with costs and the assessment is referred back to the Minister for re-assessment accordingly. 1 *S.C. 1958, c. 29. 2 73. (1) There shall be included in computing the aggregate net value of the property passing on the death of a person the value of all property, wherever situated, passing on the death of such person, including, without restricting the generality of the foregoing, (c) property disposed of by the deceased under a disposition operating or purporting to operate as an immediate gift inter vivos, whether by transfer, delivery, declaration of trust or otherwise, made within three years prior to his death; £58. (1) In this Act, (s) “value”, (ii) in relation to any other property, means the fair market value of such property, computed in each case as of the date of the death of the deceased in respect of whose death such value is relevant or as of such other date as is specified in this Act, without regard to any increase or decrease in such value after that date for any reason. 3 *3. (1) There shall be included in computing the aggregate net value of the property passing on the death of a person the value of all property, wherever situated, passing on the death of such person, including, without restricting the generality of the foregoing, (m) any amount payable under a policy of insurance effected on the life of the deceased (whether or not to a preferred bene ficiary within the meaning of any statute or law relating to insurance applicable to such policy), where such policy was immediately prior to the death of the deceased, (i) owned, either alone or jointly or in common with any other person, (A) by the deceased, 4 73. (5) For the purposes of paragraph (m) of subsection (1) (a) a reference to a policy of insurance owned by any person includes a reference to a policy of insurance in which that person had such an estate or interest or in relation to which he had such a general power as would, if he were sui juris, have enabled him either alone or in concert or by arrange ment with any other person to do any one or more of the following things: (i) change the beneficiary, 5 *4. (1) Notwithstanding section 3, there shall not be included in computing the aggregate net value of the property passing on the death of a person the value of any such property acquired pursuant to a bona fide purchase made from the deceased for a consideration in money or money’s worth paid or agreed to be paid to the deceased for his own use or benefit, unless such purchase was made otherwise than for full consideration in money or money’s worth paid or agreed to be paid as hereinbefore described, in which case there shall be included in computing the aggregate net value of the property pass ing on the death of the deceased in respect of the property so acquired only the amount by which the value of the property so acquired com puted as of the date of its acquisition exceeds the amount of the con sideration actually so paid or agreed to be paid. 6 * Compare paragraph 7 of the agreed statement of facts, “The purpose for which the deceased give to his wife the cheque for $6,076.50 was to enable her to pay him the sum of $4, 550 (the cash surrender value of the policy)....” ...

W. ½ of Lot 27 Con VII” (I think ‘‘ JK’’ signifies James Karfilis, the respondent.) ... It was in the general area or the strike so — Q.... then would it be fair to say that — what brought you “ into this area was this Raglan discovery? ... Wright: ‘ Provided that the optionee shall—’ Q. This is on page what? ...

Prior to selling the said house, it was appraised by independent appraisers at Hamilton Loan & Investment Company, of Sarnia, Ontario, at an appraised selling price of $20,012. ... It indeed appears clearly that the indemnity paid to the appellant in respect of the capital loss sustained upon the sale of his house when transferred, cannot reasonably be regarded as falling within any of the following categories: (1) ‘ as consideration or partial consideration for accepting the office or entering into the contract of employment’’ as the evidence discloses that it had nothing to do with his engagement as an employee; (ii) ‘as remuneration or partial remuneration for services as officer or under the contract of employment’’ as the evidence discloses that the appellant was receiving under his service contract the full salary appropriate to his appointment. ... Kinder (supra) at p. 692) ‘‘be treated as referable to services or as made to the employee in that capacity ’ ’ if the payment is motivated or caused by reasons of efficiency or even of mere compassion, In this vein, it should not be irrelevant to point out in passing, that if a certain class of taxpayers in this country are required, in order to earn their emoluments of office or of employment, to incur certain expenses, reimbursement of these expenses should not be considered as conferring benefits under Section 5(1) (a) of the Act. ...

The authorized capital was increased by 100,000 preference ‘ ‘A” shares of $1 each and each of the children who had now become of age, received preference “A” shares for the transfer of the assets respectively made by them. ... Jones, [1930] A.C. 415 at 423: “... The fact that a man does not mean to hold an investment may be an item of evidence tending to show whether he is carrying on a trade or concern in the nature of trade in respect of his investments, but per se it leads to no conclusion whatever. ’ ’ And then Lord Carmont stated, at page 392: “I do not wish, however, to read this passage out of its context and without regard to the facts then under consideration, and I draw attention to Lord Dunedin’s language being used with reference to ‘an investment’, meaning thereby, as I think, the purchase of something normally used to produce an annual return on such lands, houses, or stocks and shares. ...

:—This appeal was heard in Vancouver and the evidence and argument submitted were identically the same as that submitted in the appeal of the Army & Navy Department Store Limited v. ... My decision in the appeal submitted to this Court by the Army & Navy Department Store Limited was filed on this date and a copy of said decision is attached hereto. ...

:—This appeal was heard in Vancouver and the evidence and argument submitted were identically the same as that submitted in the appeal of the Army & Navy Department Store Limited v. ... My decision in the appeal submitted to this Court by the Army & Navy Department Store Limited was filed on this date and a copy of said decision is attached hereto. ...

A notice of assessment under Section 12 of the Hstate Tax Act was prepared, is dated February 27, 1964 and was addressed and sent to ‘‘ Executors, Est. of Bernard E. ... SMITH the following arrears of Estate Tax INTEREST ASSESSMENT DATE TAX PENALTY INTEREST COMPUTED TO 27 Feb/64 $7,890.30 — $1,517.52 15 Sept/65 Constituting a total amount of $9,407.82 together with additional interest at the rate of 5% per annum on the sum of $7,890.30 from 16th day of. ... This writ of extent was served upon the Toronto firm of Peat, Marwick, Mitchell & Co., Certified Public Accountants, Prudential Building, King and Yonge Streets, Toronto 1, Ontario which the applicant by affidavit alleges is associated with the New York firm of Peat, Marwick, Mitchell & Co. of which the applicant is a partner but which is a separate and distinct firm from the Toronto firm. ...

& N. 768; 157 E.R. 678; Commissioners of Inland Revenue v. Ramsay, 20 T.C. 79; Commissioners of Inland Revenue v. ... & M. Leeper to advise us. 3. Set up negotiation to avoid setting a floor for G.P. to sell to someone else. ... His further memorandum dated January 21, 1964 states, under the heading ‘‘Payment Terms’’: 7 to 10 years — 7.5 years preferred. ...

“In Kelsall Parsons & Co. v. Inland Revenue (1938) (21 Tax Cas. 608), Lord Normand (Lord President), said at p. 619: ‘... no infallible criterion emerges from a consideration of the case law. ... Fir & Cedar Lumber Co., Ltd., [1932] A.C. 441 and J. Glik- sten & Son, Limited v. ... The Northfleet Coal and Ballast Co., Ltd. (1927), 12 T.C. 1102; Bush, Beach & Gent Ltd. v. ...

L’alinéa (a) du paragraphe 1 de l’article 13 de la loi stipule ce qui suit: “... ... A la page 402 du rapport il est dit I [1928-34] C.T.C. 48]: “... The primary object of its incorporation was to enable its members, who were Saskatchewan grain growers, to market their grain co-operatively. It was assessed for income under the Income War Tax Act (R.S.C. 1927, c. 97) in respect of certain sums which it retained, from the gross returns of sale of grain, as a commercial reserve ’ and as an ‘ elevator reserve’. ...