Search - 报销 发票日期 消费日期不一致

D’Arcy J stated (at paras 40, 43 and 53 … [T]he Respondent accepts that the Appellant carried on a business in Canada and that this business included research related to improvements in cardiac surgical methodology. ... Lamy is the only employee of the Appellant, clearly he is the only one conducting the business of the Appellant, namely performing surgery, providing care to patients and conducting medical research.. … Dr. ...

. … The reassessment of SaskCo was a protective assessment issued by the Respondent as an alternative assessment to be relied upon if AgraCity prevailed in its appeals. … In the Respondent’s written submissions filed following the conclusion of the evidence and days in advance of oral argument, it indicated to the Court and the Appellants that it was conceding the SaskCo appeal. ...

After finding that reassessment of the gains for the 2007, 2008 and 2009 taxation years were statute-barred, D’Auray J went on to find that the gains for 2011 and 2012 were on income account, stating (at paras 101, 103): … I am of the view that Mr. ... If it was not his primary intention, then the possibility of reselling them at profit was certainly a secondary intention motivating him to purchase both houses. … Mr. ...

[A]s expressed in Bernick … “an accounting method that cannot possibly produce an accurate result can never meet the Canderel standard.” … [A]n unintentional understatement of the cost of goods sold in its 2010 and 2011 taxation years cannot be remedied by an intentional overstatement of the costs of goods sold in its 2012 taxation year. ...

Parker and other circumstances … cry out for relief to be granted to the Appellant, such relief … is within the purview of the Minister, not the Court. ...

In confirming their deductibility, Masse DJ stated (at para. 50): … The repairs effected by the Appellant did not result in the creation of a different capital asset than what was there before. … They were meant to bring the property to the state that it previously was. ...

. … While the law has made a distinction where someone in business is simply maintaining or somewhat extending existing knowledge and skills by, for example, taking a continuing education course within their existing field, that distinction has no application here given that the Appellants were not previously involved in real estate …. ...

. … However, taking into account the language of the rest of the subsection, I am of the view that exceptional or extraordinary circumstances must exist before the Court exercises its discretion. … In explaining the increase to 85%, she noted that the Crown had not admitted that the homes were owned in equal co-ownership by the taxpayer and his wife, rather than by the taxpayer alone, until one week before trial, even though this fact had been admitted in the discoveries by a CRA representative more than a year earlier. ...

Vocan submitted that its facility was a health care facility, being “a facility … operated for the purpose of providing medical … care,” so that its supply of the reports was exempted under Sched. ...

. … The standard imposed by paragraph 298(4)(a) is not one of perfection. … [T]he mistake made by Mr. ...