Search - 报销 发票日期 消费日期不一致

In Cybulski, this Court considered the common-law standard, being that of the “ordinary” person who ”... need not exhibit a greater degree of skill than may be reasonably be expected from a person of his knowledge and experience” and the statutory standard, being that of the “reasonably prudent" person. ... Exhibit A, entitled "Reconciliation of corporate assessment to section 227.1 assessment" furnishes precise dollar amounts of federal tax and penalty for “bank chargeback current year cheque (June remit)” and “ ailure to remit from August/December 1987”. ...

It must be borne in mind that the expression “ reasonable expectation of profit" is lifted from the definition of“ personal or living expenses”, in section 248 of the Income Tax Act. ... I shall deal with the matter as if the Minister’s use of the expression “reasonable expectation of profit” were justified without reference to the definition of “ personal and living expenses”. ...

Cogan noted that the Canadian Institute of Public Real Estate Companies ("CIPREC") has recommended that carrying costs on land held for development be treated as part of land costs and therefore be “ apitalized”. ... Subsection 9(1) provides “... a taxpayer's income for a taxation year from a business... is his profit therefrom... ...

Subsection 108(1) of the Income Tax Regulations reads as follows: 108. (1) Amounts deducted or withheld under subsection 153(1) of the Act shall be remitted to the Receiver General on or before the 15th day of the month next following the month in which the amounts were deducted or withheld. (1.1) Notwithstanding subsection (1), where the average monthly withholding amount of an employer for the second calendar year preceding a particular calendar year is not less than $15,000, amounts deducted or withheld from payments described in the definition “ remuneration” in subsection 100(1) made in the particular year by the employer shall be remitted to the Receiver General (a) for payments made before the 16th day of a month, on or before the 25th day of the month; and (b) for payments made after the 15th day of a month, on or before the 10th day of the following month. 4.02 Analysis 4.02.1 The mechanism described in the Regulations seems clear: the criterion for determining whether a company must remit on a bimonthly basis is that the monthly withholding amount of an employer for the second calendar year preceding a particular calendar year be not less than $15,000. ... This is the response of someone who is unaware of the real reason. 4.02.4 Counsel for the respondent filed with the Court the document issued by the respondent, entitled, “ Payroll Deductions—Tables". ...

ARTICLE III: The Purchaser will: (a) Pay the Contractor for the materials furnished and the work performed under this agreement, the sum of $56,000, subject however, to the additions and deductions (if any) to be made pursuant to this agreement, and payment shall be made in the proper manner following: Price of land (if supplied by Contractor) $13,000 Price of Building (See Schedule "A") $43,000 Price of Extras nil Total Contract Price $56,000 + M.L.F. ... M.N.R., the appellants sought to deduct “ soft costs" incurred in respect of a multiple unit residential building. ...

Shefner & Co. Ltd. Bar Dan Realties Inc. Ariel Realties Inc. Ascot Construction Ltd. ... Shefner & Co. Ltd. whose business is described in the T-2 return, “Steel Warehouse", the perusal of its profit and loss statements for its taxation years 1973, 1974, 1975, 1976, 1981 and 1982, showed that the company was involved in sales of lands in some of those years while in other years, for instance in 1981 and 1982 there were no sales. ...

Assessments December 4, 1985 $35,759.42 May 1, 1986 859.31 Payment received Dec. 13, 1985 (1,461.33) Interest 45.00 Total Assessed $35,202.40 (i) In response to the Notice of Objection filed with the respondent by the Appellant, the respondent re-examined the estimates in relation to the 1982, 1983 and 1984 taxation years and determined the following: (i) a review of all the T-4 slips that could be located indicated that a total of at least $5,169.54 ought to have been remitted by Granville Ltd. in 1984 and, though the respondent could not determine if this represented all of the deductions made, he satisfied himself that this represented a reasonable amount of remittances for 1984; (ii) as only one T-4 slip issued by Granville Ltd. in 1983, representing total remittance of $243.08 could be located, the respondent satisfied himself that 80% of the 1984 remittances would be a reasonable remittance amount for 1983; (iii) as no T-4 slips issued by Granville Ltd. could be located for 1982, the respondent satisfied himself that 80% of the 1983 remittances would be a reasonable remittance amount for 1982; (j) Based on the determinations detailed in subparagraph (i) above, Granville Ltd. failed to remit federal income taxes deducted and withheld from employees' wages and salaries to the Receiver General as follows: Year Amount not Remitted 1982 $2,114.06 1983 2,642.66 1984 1,787.89 1985 2,053.88 $8,598.49 (k) On December 10, 1985, Granville Ltd. was placed into bankruptcy by the Continental Bank of Canada, and Coopers & Lybrand Ltd. was appointed as Trustee; (l) The respondent filed a Proof of Claim with the Trustee in Bankruptcy dated January 6, 1986 for the amount of Granville Ltd.'s liability as detailed in paragraph 4(e), above; (m) The Appellant was an incorporating director of Granville Ltd. in 1981 with David Joudrey and William McKee. ... There exists, as was decided by Chief Judge Couture, of the Tax Court of Canada in the reported case of Fancy & Fancy v. ...

.: — Dale Pilling and his wife, Heather Pilling, appeal from income tax assessments dated May 2, 1986, in which they were each assessed penalties and interest in the amount of $27,170.68 pursuant to subsection 227.1(1) of the Income Tax Act ("Act"). In 1982 the appellants were directors of Gilmour Construction & Engineering Co. ...

As a result of the information he had received from the L.S.M. shareholders — and at that time he was unaware of the documentary evidence as produced in Court — he concluded that the $23,500 should have been used for purchases and accordingly he entered it under purchases. ...

Only one signed offer was received — in May 1980 — but was not concluded; there were discussions with two or three other interested parties. ...