Search - 报销 发票日期 消费日期不一致

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Furthermore, … without having made an oppression claim, Mr. Abenaim would never have received an amount of [confidential]. … … Schwartz indicates that, where it is established that a payment has a dual aspect, the bar for determining its allocation is not that high. … In this case, I am of the view that the best approach in determining the breakdown of the amount received by Mr. Abenaim is to refer to the civil action. … The [confidential] amount is well in excess of the amounts accorded by the courts in Quebec…. ... Abenaim. … According to the judicial guidelines, compensation in lieu of notice in this case would be $390,000. ...

This is what Jayco is asking the Court to do. … In essence, Jayco is submitting that the Minister ought to have exercised her discretion differently and not taken any collection action on the GST/HST assessed. ... This Court does not have jurisdiction to review the Minister’s exercise of that power—that jurisdiction rests with the Federal Court. … The Rules are clear that disbursements will only be awarded if they are essential to the conduct of the proceedings. … The interest was not paid by Jayco to establish that the Minister’s assessment was incorrect and therefore did not arise from the appeal filed before this Court. ... Interest paid to secure the GST/HST owing upon assessment is not of this nature. … ...

After noting that the pleadings of both parties effectively required him to treat the Appellant as making a single compound supply to Access, Graham J found, notwithstanding the provision of the cash by the Appellant to the cardholder, that such single supply was a taxable supply, stating (at paras. 138, 155, 158): … I find that [the cardholders] … paid the surcharge fee to Access for arranging for the transfer of money, not to the Appellant for transferring the money. … Access benefited from having the Appellant transfer the money. ... This was the predominant element of the supply it received …. … [T]he predominant element of the single compound supply made in the Subsequent Periods was the exclusive right to place and operate ATMs at the Resort and to process all transactions arising therefrom. This licence is a taxable supply …. Graham J also found (at para. 18), that of the words in para. ...

She completed the sale of all the shares to the purchaser and used ½ the proceeds to repay the note. ... That said, the sale of ½ of the taxpayer’s shares to her for a note clearly was a tax avoidance transaction (para. 53): Ms. ... Favreau J went on to find that there was an abuse under s. 245(4), so that the s. 245(2) assessment of the taxpayer to include all (rather than ½) of the taxable capital gains in his hands was confirmed. ...

. … … [T]here is no power given to the Minister to re-designate a consolidated trust as multiple trusts in the event that the conditions set out in paragraph 104(2)(b) are no longer met in a subsequent taxation year, nor is any process for applying for a re-designation provided. … … Had the purpose of the provision been to create an annual test, one would expect to find some indication that the designation would be done annually, or that it could be revoked at some future point. Paris J concluded (at para 24): … [T]he entire class of children and grandchildren are not income beneficiaries of each trust. Rather, a different part of the class is named in each of the trusts. … Therefore the trusts are not conditioned so that the income will ultimately accrue to the same group or class of beneficiaries. ...

After stating (at para 37) that “ medical appointments in paragraph 118.3(1.1)(d)… would not include an appointment where there is actual treatment or testing that is part of the treatment,” Jorré J went on to find that the taxpayer spent more than 14 hours per week on qualifying therapy, as required by s. 118.3(1)(a.1), stating (at paras 41, 42, 44 and 48): … The medical formula is given in very precise doses four times a day and administering it is no different from administering any other prescription medication. … [T]he time spent relating to the blood tests and to the administration of the formula can be counted as part of administering the therapy. … … While Phe is an element of nutrition, the activities necessary to assure precise delivery every day of 300 milligrams of Phe to the child, and no more than 300 milligrams, are much more akin to the administration of a medication than to the management of a diet. … [M]easuring and controlling Phe intake is properly characterized as administration of the therapy and not as control of X’s diet with the consequence that the correct way to apply these rules [in subsection 118.3(1.1)] is to consider that the time spent determining the amount of Phe to be consumed and actually consumed, including the time spent logging Phe intake, should be considered as part of the 14‑hour a week average. ...

. … He played poker non-recreationally for the purpose of making a profit. He organized his life around poker. … The appellant's poker playing activities were his main source of income during the years in dispute. … [T]he Appellant spent almost all of his time playing poker. An analysis of FullTiltPoker and PokerStars records revealed that the Appellant frequented these online poker sites on a near-daily basis and frequented one of the two gambling sites, often both sites, for … an average of 274 days per year. … Despite his unusual lifestyle and his propensity for always wanting to play at the high-stakes tables, the appellant was a serious businessman. … He avoided playing against certain opponents and he adjusted his play to his bankroll to avoid overly perilous situations. ...