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TCC (summary)

Severinov v. The Queen, 2013 DTC 1230 [at at 1260], 2013 TCC 292 (Informal Procedure) -- summary under Paragraph 118(1)(b)

The Queen, 2013 DTC 1230 [at at 1260], 2013 TCC 292 (Informal Procedure)-- summary under Paragraph 118(1)(b) Summary Under Tax Topics- Income Tax Act- Section 118- Subsection 118(1)- Paragraph 118(1)(b) "any time in the year" "throughout the year" The taxpayer appealed the denial of Canada child tax benefits and child tax credits. ...
TCC (summary)

Mariano v. The Queen, 2015 DTC 1209 [at at 1331], 2015 TCC 244 -- summary under Ownership

See summaries under s. 118.1 total charitable gifts and s. 104(1). ...
TCC (summary)

Arvisais v. MNR, 93 DTC 506, [1993] 1 CTC 2473 (TCC) -- summary under Subsection 163(2)

In finding the taxpayer liable for the penalty, Dussault J. stated (pp. 509-510): "... ...
TCC (summary)

Delle Donne v. The Queen, 2015 TCC 150 -- summary under Subsection 171(1)

The Queen, 2015 TCC 150-- summary under Subsection 171(1) Summary Under Tax Topics- Income Tax Act- Section 171- Subsection 171(1) reserve could be claimed on appeal Respecting an argument that the taxpayer was required by s. 20(1)(l) or (p) to have "included" the interest in income before being entitled to the reserve whereas, in fact, neither income nor deduction appeared in the return (although an explanatory letter was attached)- Owen J stated "in any event…it is well established that it is open to a taxpayer to amend his return through the appeal process [citing Imperial Oil, 2003 FCA 289, at para. 10]" (para. 91). ...
TCC (summary)

Gleig v. The Queen, 2015 TCC 191 (Informal Procedure) -- summary under Regulation 3100

See summary under s. 237.1(1) tax shelter. ...
TCC (summary)

Scarlet Nelson/ Larry Nelson v. The Queen, 2011 TCC 223 (Informal Procedure) -- summary under Section 201

The registrant's business usage was only 54%, which was clearly not " all or substantially all" of the use of the vehicle. ...
TCC (summary)

Green v. The Queen, 2016 DTC 1018 [at 2629], 2016 TCC 10 -- summary under Paragraph 111(1)(e)

The Queen, 2016 DTC 1018 [at 2629], 2016 TCC 10-- summary under Paragraph 111(1)(e) Summary Under Tax Topics- Income Tax Act- Section 111- Subsection 111(1)- Paragraph 111(1)(e) limited partnership losses flow through a 2-tier LP structure Paris J found that the business losses of a limited partnership allocated to an upper-tier partnership in excess of its at-risk amount continue to be business losses in its hands, so that such losses can, in turn be allocated to the partners in the upper-tier partnership so that, if the at-risk amount rules apply, it is only to restrict the losses that are allocated to the partners in the upper-tier partnership. ...
TCC (summary)

Reynolds v. The Queen, 2015 DTC 1119 [at 749], 2015 TCC 109 (Informal Procedure) -- summary under Paragraph (b)

The Queen, 2015 DTC 1119 [at 749], 2015 TCC 109 (Informal Procedure)-- summary under Paragraph (b) Summary Under Tax Topics- Income Tax Act- Section 122.6- Shared-Custody Parent- Paragraph (b) 33-49 split was not “equal or near-equal” basis The taxpayer took care of her two step-sons for approximately 33% of the hours in a given two-week period, while her spouse's ex-wife took care of them for approximately 49% of the time the balance being taken up by school. ...
TCC (summary)

Hamilton v. The Queen, 2010 TCC 591 (Informal Procedure) -- summary under Residential Complex

. …. The portion of the lot that he sold together with the house was attributable to the use of the house and was reasonably necessary for its use and enjoyment as a place of residence for individuals. ...
TCC (summary)

Tournier v. The Queen, 2018 TCC 229 (Informal Procedure) -- summary under Income-Producing Purpose

After noting that retention of the client files was professionally recommended, Bocock J stated that deductibility was “consistent with the notion of unavoidable expenses necessarily expended in future years referable to previous income contemplated in Poulin, Raegele and Langille.” ...

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