Search - 报销 发票日期 消费日期不一致

For example … there may be an interrelationship between the Appellant’s acquisition of the investment management services and its resupply of such services to the Pension Plans. … The Court cannot answer the Rule 58 Question … in a factual vacuum. ...

It turns to Rule 30(2), which provides how a corporation may appear in person in the Tax Court of Canada – by means of leave of a judge of the Court with possible conditions. … Yes, there is common law jurisprudence to the effect that “in person” can only mean by the presence of a visible person … but there has been no such jurisprudence, until Masa Sushi, from the Tax Court of Canada. ...

In allowing her cliams, Bocock J stated (at paras. 12 and 13): … [T]he Lawyers Insurance Association of Nova Scotia (“LIANS”). ... Moreover, there are elaborate and precise directives for files which may be scanned, may be destroyed and must be kept indefinitely. … [T]he files should be readily available where necessary and needed to mitigate legal liability arising from premature destruction, mindful of relevant limitation periods. … Both the past accrual of future record keeping services, the file storage, and the need to protect presently her insurance coverage for past legal services all represent the enduring and current provision of legal services (“continuing services”) beyond the temporal period in which the income was received: the year in which it was otherwise earned and recorded. ...

Smith J indicated that the jurisprudence was unclear whether s. 296(2.1) could be applied to require CRA to grant an offsetting credit for the NRRP rebate when it assessed Poirier to deny the new housing rebate – so that he did not foreclose the possibility that s. 296(2.1) could thereby overcome the two-year deadline. ... On the one hand, it is suggested that the off setting provisions in subsection 296(2.1) are not available when a rebate application has been dealt with under subsection 297(1) …. On the other hand, it is suggested that those provisions may be available in certain circumstances …. ...

In 2010, the Minister assessed the Henro (to include an income account gain) and 984 (to reverse the previously reported capital gain and refund the capital gains tax) on the basis that the 2003 drop-down had occurred on a non-rollover basis – but its assessment of 984 was found to be void as being statute-barred. ... However, the resulting 2015 reassessment of 984 could not be justified as valid based on s. 169(3) because the 2010 assessment was itself invalid – hence, 984 was not an appealing “taxpayer” referred to in s. 169(3) (as it was not engaged in a valid appeal procedure). This meant that the only basis for justifying the 2015 assessment of 984 was that, pursuant to s. 160.1(1), the 2010 refund represented an amount that had been “refunded to a taxpayer … in excess of the amount to which the taxpayer was entitled as a refund under this Act.” ...

The Queen, 2019 TCC 109 (Informal Procedure)-- summary under Paragraph 256(2)(a) Summary Under Tax Topics- Excise Tax Act- Section 256- Subsection 256(2)- Paragraph 256(2)(a) larger weekend country home was not their primary place of residence The taxpayer and her husband built a house, which was near Lake Huron and a 2 ½ hour drive from their Brampton rental apartment and full-time employment, doing a large portion of the work themselves on weekends beginning in 2008, with the intention to retire there. ... This last consideration regarding time spent in each location is very important and must be given great weight. … [T]he Appellant and her husband may retire approximately two years after the hearing of this matter. This would be 6 ½ years after substantial completion....[T]his is too far in the future. ...

. … [T]he parties are not the same in the Tax Court Appeal and the U.S. ... Class Action concerns a breach of U.S. securities law that allegedly occurred beginning in February of 2011. … [T]he Non-parties have not been able to refer to a specific document in this appeal whose disclosure would be in the public interest. … [T]he Non-parties’ motion is a fishing expedition…. ...

I also conclude … that these expenses were reasonable. … [T]he Appellant testified that after he paid for a room, he had approximately $20 to $30 remaining for meals per day and that, on many occasions, he had to personally subsidize the cost of his food. … I see no reason why the term “travel expenses” cannot be interpreted to include these meal expenses, when they are reasonable and provided at the remote work location. ...

. … … Mr. White did not defeat or in any way hinder the Minister’s efforts to collect any tax he owed by placing his remuneration in the Joint Bank Account. The Minister could have taken collection action with respect to funds in the Joint Bank Account. … Once the funds were placed in the Joint Bank Account, the Appellant had the ability to effect a transfer; however, such transfer did not occur until the Appellant removed the funds from the account. ...

. … [T]he error was obvious and … if Mr. Tremblay and Mr. Forest [the CEO and CFO] had checked the return, they would certainly have detected the error since they were both CPAs and it was fairly straightforward to ensure that the dividends were included. … In my view, the failure to review the appellant's income tax return and the failure to question the accountant to ensure the accuracy of the information contained in the return demonstrate a lack of due diligence on the part of the appellant's officers. ...