Search - 微信撤回和删除的区别 官方

. … Regarding the IPT, section 527 of the QSTA clearly provides that the insurer, in its capacity as agent, must account for the tax collected in the preceding calendar month at the end of the month. ...

. … There is a direct link between the PCB Points that are issued in conjunction with an exempt financial service supplied by PC Bank to Cardholders and an expense that is paid when the PCB Points are redeemed by Cardholders. ...

. … In this case, the appellants could revoke the designation of R3D as beneficiary at any time, but this is a right that flows from the insurance contract. ...

. … In also finding that the Court below had not erred in declining to exercise its residual discretion to permit the ITC claims (viewed as a post-filing claim) against the tax owing, he stated (at para. 48) that this would have been “inconsistent with the remedial objectives of the CCAA, regardless of whether the focus is on restructuring the debtor’s affairs or on liquidation.” ...

Before remitting the adverse decision of the CRA review officer for decision by another officer, Southcott J noted that the CRA position- that the taxpayer had not made a reasonable error (the first element of s. 204.1(4)) given that the taxpayer was notified of his contribution on a sufficiently timely basis that he could have gone back to RBC to correct its reporting of the contribution while it still had sufficient records of the transaction – was not supported by the record, which did not establish that CRA had notified the taxpayer of his alleged over-contribution in 2013 before December 2020. ...

. … [I]n tax matters, where the federal and provincial provisions are appreciably in the same form, a presumption of coherence between the two provisions should prevail. ...

. … Further, once the respondents were swayed to buy into WTC’s plan by the thought of turning an unexpected profit out of their crystallized tax liability through what they viewed as a risk-free exercise, they became the instruments through which WTC, acting as the sole mastermind, would lay its hands on the $1.3 million [equal to the tax liability], isolate it with the remaining cash in the subsidiaries and share it with the respondents in the proportion that it imposed. ...

He accepted (at para. 26) the “frustrating event” doctrine from Sazio (2018 TCC 258), but stated (at para. 26): To invoke frustration, the surrounding circumstances must make the frustrating event unforeseeable, beyond the buyer’s control, and deny the buyer any alternative pathway to having the property be their primary residence …. ...

Regarding the Reg. 2401(2)(d) designation, the text and legislative history supported the view that the insurer had the discretion to designate Excess CIF in respect of any of its insurance businesses – even an insurance business (here, the A&S business) that was exempted from tax. ...

(r.5) of an exclusion from a financial service for the delivery of property “in conjunction” with one of the listed services, was applicable agreed (at para. 56) with the view of Hogan J that “the addition of new paragraphs (r.4) and (r.5) to the definition of financial service … raises a new issue of whether, in light of these new provisions, PC Bank was providing a financial service to CIBC” i.e., the 2009 Decision and this appeal did not deal with an identical issue ...