Search - 报销 发票日期 消费日期不一致

Zelinski had been listening to “Sunday Morning Magazine” on CBC Radio that very morning and had heard a lengthy report on Norval Morrisseau — his prominence within Canada- his international reputation — his founding of the “Woodland School” — and the acquisition of his works by collectors and galleries. ... And frankly, sir, I think that towards the end, everyone of us — not even towards the end. ... Value as Expert Cost to Cost as % Multiple Valuation Appellants of Value of Cost Witness Moos (PADAC) $ 990,000 $130,000 13.2% 7.6 Robinson 1,105,000 130,000 11.8% 8.5 Lake/McLeod 510,000 130,000 25.5% 3.9 Although Mr. ...

Accordingly, he was required to sign an acknowledgement which was entered as Exhibit R-15 stating: I, Shih Min Shah, acknowledge and am fully aware that my admission to Canada for permanent residence as an entrepreneur is based on the following terms and conditions as stipulated in section 23(d) (iv) A & B, of the Immigration Regulations, namely that within twenty-four months from the date of landing: A) he establish, purchase or make a substantial investment in a business or commercial venture in Canada that will make a significant contribution to the economy and whereby employment opportunities in Canada are created or continued for one or more Canadian citizens or permanent residents, other than the entrepreneur and his dependants, and B) he participate actively and on an on-going basis in the management of that business or commercial venture. ... The major – I like to send my kids in Canada to learn in a more western educational system. ... Therefore, I propose to consider first the Appellant's argument to see if a case can be made for the Appellant's residence in Taiwan. [17] Using Exhibits R-14 and R-15 as evidence that the Appellant and his wife and their three children arrived in Canada on August 11, 1991, and using Exhibit R-10 as evidence of the number of days that the Appellant spent in Canada during the four years under appeal, I have prepared the table below to compare the days the Appellant spent in Canada with the days he spent in Taiwan: Year Total Days Days in Canada Days in Taiwan Time in Canada 1991 142* 32 110 22.5% 1992 366 59 307 16.1% 1993 365 51 314 14.0% 1994 365 43 322 12.0% * August 11 to December 31 = 142 days [18] The above table speaks for itself but certain facts are worth noting. ...

On September 17, 1980 Gillies received a follow-up letter from Coopers & Lybrand, included with which was a summary of "the transactions that are to be concluded before the end of this month”. ... Shantz in turn owned 1,440 of 3,000 issued shares of Trend-Line Glass & Mirror Inc. ... And you have heard the names Laramee Trucking and Trend-Line Glass & Mirror? ...

Thompson & Sons Ltd. v. M.N.R. (1966), 41 Tax A.B.C. 1, 66 D.T.C. 291; Admiral Steel Products Ltd. v. ... M.N.R., [1984] C.T.C. 2189, 84 D.T.C. 1140 (T.C.C.); Installation Mécanique G & B Ltée v. ... Thompson & Sons Limited v. M.N.R., supra. If one were to retain the ordinary meaning of the word "processing" as the only guide to its interpretation there would, of course, be very little in our society that could not be categorized as some form of processing. ...

A return of income for each taxation year in the case of a corporation... shall, without notice or demand therefor, be filed with the Minister in prescribed form containing prescribed information, Subsection 150(1) Income Tax Act 24) As a consequence of the fact that Holdco had never filed income tax returns as required by subsection 150 (1) for the taxation year which commenced October I, 1987 and terminated on October 15, 1987 and for the taxation year which commenced on October 16, 1987, the Appellant prepared and filed the three income tax returns and accompanying financial statements on behalf of Holdco, filed June 1 1994, for the following three periods respectively: • October 1, 1987 to October 15, 1987 (Document 2); ° October 16, 1987 to October 31, 1987 (Document 3); • November 1, 1987 to September 29, 1988 (Document 4). 25) The first of these income tax returns reflect the normal taxation year of Holdco which began on October I, 1987 and which was terminated as a consequence of the acquisition of control [of] Holdco on October 16, 1987. ... Paragraph 249(4)(d) 28) The third of these income tax returns represents the taxation year which the Appellant considered to commence on November 1, 1987, as a consequence of the filing of the second of these income tax returns, and which terminated at September 29, 1988 as a consequence of the amalgamation of Holdco and Old Sybron on September 30, 1988, pursuant to the provisions of paragraph 87(2)(a) of the Act which provides that the taxation year of an amalgamating corporation “shall be deemed to have ended immediately before the amalgamation ’’.... 32) That the Appellant states that Holdco cannot be taken to have adopted a fiscal period which ended at September 30, 1988 by virtue of the filing of the Original 1988 Return for two reasons. ...

Its preamble reads: WHEREAS MEREDITH and PELLEGRIN are indebted to the company in the amounts set opposite their names as follows: (As at June 26, 1987) Rice Howard Drew Meredith $110,666 Arv Pellegrin $ 99,694 AND WHEREAS the company intends to forgive the indebtedness in an orderly fashion. ... If I understand your question, you're saying where does the — do the 1988 financial statements reflect a devaluation of the company as a consequence of the forgiveness of those loans? ... Because there was — Arv Pellegrin was leaving the company and it wasn't in the — in anyone's best interest to have these outstanding debts continued. ...

And lastly, Tabs 72 to 75 are minutes of directors’ meetings of Co. 351 held on four successive years showing that dividends were declared as follows: Meeting Date Aggregate Class of Dividend Payable Dividend Shares November 30, 1988 $ 48,000 Common November 30, 1988 November 30. 1989 24.000 Common November 30, 1989 November 30, 1990 12,000 Common November 30, 1990 November 30. 199] 12.000 Common November 30, 199] There is no dispute between the parties concerning any of the documents. ... Cheque to James for his needs $3,286 Family Vacation (James’ 1/5 share of cost) 400 $3,686 Total for James $7,584 Peter- age 12 in 199] Tennis camp $ 1.500 Health club 300 Hockey representative team and hockey camp 1,500 Vacations 1.020 (Peter’s share of costs) Parents’ MasterCard 3,084 (purchases for Peter) Other 2,313 Total for Peter $9,716 Sarah- age 17 in 199] French Immersion in Switzerland Business School in Germany Total expended for Sarah $5,958 James Sarah Peter Total 199] $7,584 $5,958 $9,716 $23,258 1992 11,135 9,665 5,567 26,367 1993 19,302 13,558 6,340 39,200 Paragraph 20(1)(c) of the Income Tax Act is the provision which permits the deduction of interest. ... That purpose — and it is a practical and real one, and in no way remote, fanciful or indirect — is the importation of the losses from the U.S.... ...

The dates and amounts of the loans, and the property acquired, are as follows: Amount Property Acquired Date of Loan Borrower August 15, 1985 Old BPI $ 3,150,000 Harvest Heights Apartments Estevan, Saskatchewan August 31, 1985 Old BPI $ 4,135,000 Commerce Building Regina, Saskatchewan September 1, 1985 Village $22,500,000 Terrace Inn Hotel Gate Edmonton, Alberta September 30, 1985 Old BPI $ 1,550,000 Worldwide Energy Building Bonnyville, Alberta January 31, 1986 Old BPI $10,100,000 Maryland Office Park Calgary, Alberta June 30, 1986 Old BPI $11,500,000 Five Ten Fifth Office Building Calgary, Alberta 6. ... It was a liability — to become subject to an obligation to pay the balance if, (in this case the interest) but only if, an event occurred which was by no means certain to occur (in this case an excess of net cash flow over interest or excess of net sales value over the accrued amounts). ...

Again, there is also the fact that the text of subparagraph (s) is not reproduced, with the same result as in the Reply in the second appeal. [8] In the above-mentioned Replies to the Notices of Appeal the Court has indicated in parentheses after each subparagraph the comments made by counsel for the appellants at the start of the hearing, as follows: (A) = admitted (D) = denied Appellants' evidence According to Daniel Langlois: [9] He did in fact read the report of the appeals officer (Exhibit A-1) in his case. [10] It is true his parents initially purchased a residence known as "Le Cormoran" which they converted into an inn. [11] It is also true that Daniel Langlois then decided, along with his parents, to purchase the Domaine de la Belle Plage, a bankrupt inn located two hundred feet from Le Cormoran. That is how he came into the picture and the payer was then incorporated. [12] Le Cormoran was then leased to the payer. [13] Both businesses are of course of the Bed & Breakfast (B & B) type catering to tourists and there was duplication. [14] It was therefore decided to have a single operation and customers could have breakfast at either place without any difficulty. [15] The payer operated during the tourist season, on holidays and during school vacations. [16] There were indeed three people on the Board of Directors and they met officially from time to time to decide on opening and closing dates, on work to be done and on employees' salaries. ...

The decisions of Amden were made by the Appellant and he was its controlling mind.... p) At all times material to this appeal, more particularly from 1989 to 1992, the Appellant carried on the profession of an architect under the name, style and firm, Gordon Atkins & Associates. q) The Appellant had, in the course of years, acquired skill and expertise with regard to processing applications for the subdivision of land and also of supervising the construction of facilities such as road ways, water, power, landscaping etc. r) The Appellant participated in many subdivisions in respect of different lands at times previous to 1989. s) On June 15, 1987, Amden entered into an agreement with Wood (the "Contract") for the benefit of the Appellant in respect of a parcel of land owned by Wood in extent about 87.5 acres and legally described as the South-east quarter of Section 24, Township 24, Range 3, West of the Fifth Meridian (the "Land). ... " As he and Amden's services were used, he "... felt secure that my land bank was growing. ... ".. W " The struck out portion indicates that, at the very least, Mr. ...