Search - 广东省2025政府工作报告 一小发展 金句

1 July 2025- 11:32pm Haworth – English Court of Appeal finds that the place of effective management of trusts for treaty tie-breaker purposes was in the UK even though their CMC might be in Mauritius Email this Content The UK-resident taxpayers sought to avoid capital gains tax respecting the disposal of shares by family trusts of which they were the settlors by relying on a "Round the World" tax plan. ... He further stated: … [Here] the role of the trustees in Mauritius was effectively pre-determined. … [T]he settlors, albeit with the advice and assistance of advisers, decided to adopt "an overall single plan" and, to that end, exercised their powers to appoint the Mauritius Trustees for a limited period "in the confident expectation that they would implement the plan". ... Summary of Haworth & Ors v Commissioners for His Majesty's Revenue and Customs [2025] EWCA Civ 822 under Treaties – Income Tax Conventions- Art. 4. ...

26 January 2025- 10:47pm Vorsteveldt – taxpayers are challenging the CRA administration of the 2/3 CGIR Email this Content Ms. ... (Canada), 24 January 2025 Application pursuant to ss. 18 and 18.1 of the Federal Courts Act under s. 38(a) (see also Pelco Holdings v. ... (Canada), 24 January 2025 Application pursuant to ss. 18 and 18.1 of the Federal Courts Act). ...

4 May 2025- 11:17pm Delta 9 Cannabis – Alberta Court of King’s Bench determines that a reverse vesting order should not permit the target corporation to transfer out future s. 80 income tax liabilities Email this Content A cannabis producer (“Bio-Tech”) had entered CCAA proceedings. ... Summary of Delta 9 Cannabis Inc (Re), 2025 ABKB 52 under s. 80(13) and summary of Chris Lang, “Debt Restructuring Using a Reverse Vesting Order: Tax Issues,” Canadian Tax Focus, Vol.15, No. 2, May 2025, p. 2 under s. 80(13). ...

11 June 2025- 12:09am Shopify – Federal Court indicates that it would pare back a CRA unnamed-person requirement (if not already invalid for vagueness) because it would require 8 person-years to respond Email this Content The Minister issued a requirement to Shopify pursuant to s. 231.2 for information identifying listed particulars for all Canadian-resident merchant customers of Shopify. The requested particulars were more extensive than in the companion 2025 FC 968 case (re a treaty-based request). ... Shopify Inc., 2025 FC 969 under s. 231.2(3). ...

22 May 2025- 11:52pm Vortex – Tax Court of Canada characterizes purported SR&ED as routine engineering conducted by trial and error Email this Content In confirming the denial of the claim of the taxpayer that it had engaged in experimental development in building mobile direct-contact water heaters for use in fracking, Spiro, J. found inter alia that there was an absence of any expert evidence demonstrating technological risks or uncertainties which could not have been removed by routine engineering or standard procedures, and that the work could instead be characterized as routine engineering that was conducted by trial and error. ... The King, 2025 TCC 63 under s. 248(1) – SR&ED. ...