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FCA (summary)
Tusk Exploration Ltd. v. Canada, 2018 FCA 121 -- summary under Subsection 248(28)
Canada, 2018 FCA 121-- summary under Subsection 248(28) Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(28) potential for double taxation under the ITA of NAL transactions The taxpayer, a Canadian exploration company, unsuccessfully argued that it was not subject to Part XII.6 tax on Canadian exploration expenses (“CEE”) that it had purported to renounce under the look-back rule- but which were now admittedly not eligible for look back because the flow-through share investors were non-arm’s length – because the reference in Part XII.6 to CEE that it “purported” to renounce under the rule referred only to expenses which had been validly rather than invalidly renounced under the look-back rule. ...
TCC (summary)
Bérubé v. The King, 2023 TCC 12, aff'd 2025 CAF 112 -- summary under Business Source/Reasonable Expectation of Profit
. … Despite his unusual lifestyle and his propensity to ridicule his opponents, the appellant was a serious businessman. ...
FCA (summary)
Canada v. Sommerer, 2012 DTC 5126, 2012 FCA 207 -- summary under Income Tax Conventions
Regarding the Minister's argument that Article 13 was only included "for greater certainty," Sharlow J.A. stated: The OECD model conventions, including the Canada-Austria Income Tax Convention, generally have two purposes – the avoidance of double taxation and the prevention of fiscal evasion. ...
FCA (summary)
Thye RRSP of James T. Grenon (552-53721) by its Trustee CIBC Trust Corporation v. Canada, 2025 FCA 129 -- summary under Subsection 152(3.1)
. … Grenon RRSP was obligated to file a return under Part I reporting taxable income. ...
FCA (summary)
Thye RRSP of James T. Grenon (552-53721) by its Trustee CIBC Trust Corporation v. Canada, 2025 FCA 129 -- summary under Subsection 27(1.3)
In my view, the issue is not new …. However, even if it were a new issue, I am satisfied there is a sufficient basis in the record to resolve the issue and we have a duty to do so to ensure justice is done. ...
Decision summary
Imprimeries Transcontinental Inc. v. Agence du revenu du Québec, 2025 QCCQ 1926 -- summary under Class 29
. … The Contracts mostly provide that the customer retained, on an exclusive basis, the services of IT 2005 SENC for the printing of their flyers and other advertising products in exchange for a price they committed to pay. ...
TCC (summary)
Downtown Hockey League Ltd. v. The King, 2025 TCC 92 (Informal Procedure) -- summary under Subsection 152(3.4)
. … The same rationale applicable to income tax assessments must logically apply to CEWS determinations, namely, individual notices of determination may be appealed in a single notice of appeal without coalescing. ...
TCC (summary)
Cartier House Care Centre Ltd. v. The Queen, 2015 TCC 278 -- summary under Section 13
II, s. 1 – home care service. ...
TCC (summary)
MacDonald v. The Queen, 2012 TCC 123, rev'd 2013 DTC 5091 [at 5982], 2013 FCA 110 -- summary under Subsection 245(4)
Although the transactions entailed surplus stripping, "it is doubtful whether in an integrated corporate/shareholder tax system, a surplus strip per se can be said to abuse the spirit and object of the Act " (para. 101). ...
FCA (summary)
Canada v. Landrus, 2009 DTC 5085 [at at 5840], 2009 FCA 113 -- summary under Subsection 245(4)
(Noël, J.A. also noted (at para. 69) that the " the same terminal loss would have been realized if the limited partners, rather than proceeding with the transactions in issue, had simply dissolved the partnership and distributed the partnership assets to the partners. ...