Search - 报销 发票日期 消费日期不一致

. … It is neither unusual nor surprising that a taxpayer would incur substantial costs in the renovation of a heritage building. … He then concluded (at paras. 64 and 66) in allowing the appeal: [D]espite the use of the words “at any time” in subsection 15(1), the Court must conclude that the residual value of the leasehold improvements cannot be quantified until such time as they revert back to the Taxpayer. ...

. … [T]he fees incurred pursuing the Oppression litigation had as its dominant purpose, the intention to protect the Appellant’s interest in her shares in the corporations. ... Therefore, I have apportioned the fees in issue. … I will make an estimate that 25% of amount paid in the Oppression litigation was incurred in order to receive income. ...

The Queen, 2020 TCC 33 (Informal Procedure)-- summary under Paragraph 8(1)(b) Summary Under Tax Topics- Income Tax Act- Section 8- Subsection 8(1)- Paragraph 8(1)(b) s. 8(1)(b) did not cover legal costs of an action to extend the period of employment The taxpayer worked as a provisional judge for the Montreal Municipal Court up until 2005, and then served as a full-time judge up until 2012, at which time he was forced to resign as he had attained the age of 70 – which meant that he was 23 months short of the requisite years of full-time service required to generate a full pension. ... Clément was instead seeking was the right to hold his office beyond the age of 70 and to be reinstated in his office so that he could accumulate credits for his pension. … Respecting the second ground, she stated (at para. 29): If Mr. ...

. … Even if the supply provided by Zomaron to the Processors involved services of a promotional nature, since these do not represent the predominant element of the supply, paragraph (r.4) has no application …. ...

In rejecting the Crown’s position that the appellant was not entitled to the rebate because he had acquired the condo from the Assignor (who was not the “builder”) rather than from West Harbour, Jorré DJ stated (at paras 23, 24): Given that there was no sale from West Harbor to the Assignor, given that the Appellant made all the payments due to West Harbour under the purchase agreement arising after he signed the assignment agreement, … given the … emails showing acceptance by West Harbor of a direction coming from the office of the Appellant’s lawyer that title would be in the Appellant’s name and given the land registry records showing the transfer from West Harbor to the Appellant, it is clear from its conduct that the vendor, West Harbor, waived any unfulfilled conditions regarding the assignment, accepted the assignment and sold the property to the Appellant. ...

In finding that the taxpayer’s claimed losses (except for an overstatement of the 2002 loss due to an “egregious error” – for which a gross negligence penalty was sustained) were fully deductible, Spiro J noted- in responding to a Crown submission based on the trading consistently generating small economic losses, so that there was no source of income – that Stewart established that “provided that one’s activity is clearly commercial, and that no personal element is involved, there is a source of income” (para. 201) and made “it clear that there is no ‘sufficiency’ test” (para. 209). ...

However, the taxpayer (a Canadian resident with a French rental property), like others, was granted transitional relief so that in 2019 she received a tax credit from the French government equal to the French tax otherwise payable by her on her 2018 income – so that in 2019 she only had to pay the current tax on her 2019 rental income. ... The Tax Convention refers to income, regardless of when the tax is to be paid to or collected by the tax authorities. … Thus, since Mr. ...

Paul (together with Nancy about ¼ of the time) used a 36-foot boat, designed as a “pleasure craft,” to stay at other marinas and at boat shows, where he would mingle socially with the boaters and promote the use of the C.A.B. marina (as well as operating a promotional booth, when at a boat show). ... Boyle J stated (at paras. 20, 22): CRA has not been allowed by the courts to simply second-guess a business’s marketing strategy or efforts, even if they turn out to be unsuccessful in generating revenue. … Once it is established that business marketing activities were bona fide and primarily undertaken for business purposes, and that the expenses were themselves reasonable, it does not matter that the marketing involves socializing with clients, potential clients and/or other persons or entities relevant to its business. ...

Hogan J noted (at paras. 62, 70) that the “the Bundle of Rights … enabled CIBC to sell financial products and services” by “allow[ing] CIBC to tap into LCL’s loyal and extensive customer base.” ... For example, it could exclude from the “financial service” definition “property … that is delivered or made available to” CIBC “in conjunction with” CIBC selling PCF Products to new clients whom it recruited pursuant to the PCF Agreements (if we assume that such contractual rights are the predominant elements of the PC Bank Supply). ...

The word document [“record” in English] is [broadly] defined in subsection 123(1) …. ... The Court considers this testimony to be credible …. Appellant had therefore obtained this information prior to the filing of the 2015 annual return containing the claimed ITC. ...