Search - 微信撤回和删除的区别 官方

Before allowing the taxpayers appeal, Yuan J, stated (at para. 41): I have difficulty imagining what better evidence the CRA could reasonably expect an applicant to produce as proof of filing where the application was submitted by regular mail …. ...

The test is whether … may one say that the building was renovated sufficiently enough that all or substantially all of the building has been removed or replaced: Camiré v. ...

Smith J indicated (at para. 522) that: [T]he T3GR Return was the prescribed form intended by CRA to meet the filing requirements of RRSP trustees pursuant to paragraph 150(1)(c) and subsection 207.2(1) of the Act and section 204 of the Regulations and … it was intended as a streamlined process for the reporting of group RRSPs involving hundreds of thousands of plans under one specimen plan. ...

. … I would not expect section 141.01 to deny the input tax credits otherwise determined under subsection 169(1) in the situation where a person is only engaged in commercial activities. ...

Owen J stated (at para. 48) that "this argument fails to recognize that the Advisers are independent contractors and that their use of the subleased space is in furtherance of their own business objectives," noted (at para. 49) "that the Advisers cannot use the subleased space without also using the common-use space," and (at para. 50) that "the direct purpose of the available space was to rent the space to Advisers", which was relevant rather than "the indirect (or ultimate) purpose of having space available … to facilitate the sale of Financial Products. ...

After finding (at para. 40) that “the 2016 amendments … overrode the requirement from prior case law that the tax under the alternative argument had to be derived from the same transaction that produced the originally assessed tax”, he noted that here the alternative bases for denying the interest expense were based on the same transaction being “the borrowing that established the Appellant's obligation to pay the interest expense in the first place” (para. 41). ...

In rejecting an argument of the taxpayer based on the Irving Oil and Munich Re decisions, he stated (at para. 56): The Irving Oil and Munich Re decisions do not stand for the proposition that every decision to pay or not to pay income tax qualifies as a business decision, let alone that such decisions are made for the purpose of earning income under the principles governing section 9 and paragraph 18(1)(a) …. ...

(a)(iii)(B) includes a single individual, so it did not matter that there was only one tenant during the relevant period (para. 11); in the situation, for example, where "two individuals occupy the unit – one for a year and the other for six months –...on the basis that the plural includes the singular, the unit will qualify...by applying the test to the one individual who does occupy the unit for the whole year" (para. 12) "if there is only one occupant of a unit, in order for the unit to qualify based on the actual use test, the unit will have to be occupied by the same individual for a full period of one year (or the shorter period of time contemplated by this clause [((B)])" (para. 20) the phrase "place of residence of individuals" in s. ...

(The taxpayer testified that he spent $104,719 to install a gravel road for ¾ of the property length in order to free up a pick-up truck that had become stuck in peat.) ...

Hershfield J referred (at para. 91) to this being from the perspective of Mall Co a " quid pro quo from ICBC to forego its entitlement against Tech BC. ...