Search - 广东省2025政府工作报告 一小发展 金句

4 March 2025- 10:37pm RTI – Court of Quebec confirms that it had no jurisdiction to deal with over-remittances of source deductions Email this Content Couture JCQ confirmed that the Court of Quebec had no jurisdiction to consider a Notice Of Objection of the taxpayer based on the failure of the ARQ to refund source deductions which it alleged that it had over-remitted, given that the Quebec equivalent of ITA s. 171(1) only accorded the Court of Quebec jurisdiction to deal with assessments. ... Agence du revenu du Québec, 2025 QCCQ 231 under s. 171(1). ...

14 July 2025- 11:28pm Tremblay – Quebec Court of Appeal confirms that s. 56(2) applied to the free occupation by the taxpayer’s ex-spouse of a condo owned by a corporation indirectly controlled by him Email this Content The Quebec Court of Appeal confirmed that the taxpayer, who had agreed in connection with their separation to let his ex-spouse occupy, free of charge, a condo owned by a corporation controlled by him through a holding company, was taxable under the Quebec equivalent of s. 56(2). ... Agence du revenu du Québec, 2025 QCCA 783 under s. 56(2). ...

9 March 2025- 11:17pm 1351231 Ontario – Federal Court of Appeal confirms that conversion of the use of a condo from long-term rental to an Airbnb property caused its subsequent sale to be taxable Email this Content The Appellant used a condo unit for the first nine years after purchase for long-term residential rentals and then listed it on Airbnb and rented it out for succession of short-term rentals (under 60 days and sometimes for only one night) before its sale. ... Canada, 2025 FCA 53 under ETA s. 123(1) – residential complex. ...

25 March 2025- 11:17pm IWK Health – Tax Court of Canada finds that employers could not claim HST on the reimbursed health care expenses of their employees Email this Content Some Nova Scotia hospitals reimbursed (through a health care plan administrator) their employees for the employees’ costs including HST of acupuncture, massage therapy, naturopathy, or homeopathy services. ... Accordingly, these services did not satisfy the s. 175 test of being “for consumption or use … in relation to activities” of the hospitals. ... The King, 2025 TCC 44 under ETA s. 175(1). ...

16 January 2025- 12:17am Doostyar – Federal Court of Appeal indicates that judgments should not be provided to the parties in draft for non-substantive comments Email this Content The Tax Court judge sent a draft judgment (disallowing the taxpayers’ appeal) to the parties and asked for their comments on any “typographical, grammatical, punctuation, or [any] similar error[s] or any omissions” and any “comments in respect of the written presentation of…[the] decision”, but not so as to revisit the substance of the decision. ... Canada, 2025 FCA 6 under s. 171(1). ...

24 March 2025- 11:12pm Excavations Marchand – Court of Quebec finds that a construction company’s equipment used to provide concrete at a construction site qualified as for manufacturing goods for sale Email this Content A construction company contracted with Hydro-Quebec for the installation and operation of an on-site portable concrete-producing facility for the provision of the concrete in the installation of a large hydro-electric dam at a remote location. ... Agence du revenu du Québec, 2025 QCCQ 378 under Class 29 and Reg. 1104(9)(c). ...

27 July 2025- 11:32pm Pommet – Court of Quebec finds that a former Quebec resident spending significant time in Quebec, supervising rental properties and hunting, was an Ontario resident Email this Content The taxpayer was found to be resident in Ontario, given that he considered his farm in Ontario, which he had acquired in 2015 a number of years after separating from his Quebec wife (leaving independent adult children in Quebec), to be his home, notwithstanding that he spent around 100 to 120 days each year in Quebec to supervise his residential rental properties there and to spend time at his Quebec hunt camp, and his riverside chalet for duck hunting. ... Agence du revenu du Québec, 2025 QCCQ 2592 under s. 2(1). ...

23 June 2025- 12:02am St-Joseph – Quebec Court of Appeal finds that the transformation of 2 floors of commercial building to residential use did not qualify as a “termination” of commercial activity for QST purposes Email this Content St-Joseph incurred costs in converting the 1 st and 2 nd floors of a 12-storey mixed-use tower from commercial rental use into rental seniors’ residences (RSRs). ... In rejecting this position and before dismissing St-Joseph’s appeal, the Court stated: [Its] argument … fails to explain how the transformation aimed at a new activity is, in itself, related to the termination of the previous activity. … [T]he expenses for the renovation and transformation into an RSR were not related to the termination of the commercial rental activity …. ... Agence du revenu du Québec, 2025 QCCA 745 under ETA s. 141.1(3)(a). ...