Search - 报销 发票日期 消费日期不一致
Results 12731 - 12740 of 13535 for 报销 发票日期 消费日期不一致
TCC
Pioneer Designs Corp. v. MNR, 91 DTC 293, [1990] 2 CTC 2446 (TCC)
At all material times, the appellant's five directors were those mentioned below and opposite each name is shown the percentage in the appellant's shareholdings held directly or indirectly by each director from the time of incorporation to October 29, 1986: Laurent Lebel 20 % Connie Laidlaw 20% Frank Mueller 16.7% George Mueller 10% Gerald Metheral 33.3% George Mueller and Gerald Metheral were respectively appointed president and secretary of the appellant, as appears from a resolution dated November 20, 1978. ... In this connection, the financial statements of the appellant also show that the following management fee expenses were paid by the appellant to Delco in respect of the appellant's taxation years mentioned below: 1981 $ 97,735.44 1982 $115,021.23 1983 $107,437 1984 $ 29,400 1985 $ 23,705 With respect to management fees, the financial statements for the year ended October 30, 1984 reflect a change in accounting practice. ...
TCC
Low v. The Queen, 93 DTC 927, [1993] 2 CTC 2227 (TCC)
:—This appeal involves an assessment by the Minister of National Revenue (" Minister”) dated July 5, 1990. ... (Ontario: Carswell, 1993) Title 28, “ Conflict of Laws", at page 161, paragraph 275, counsel states: The general principle of the common law is that the law of the place where immovable property is situate governs exclusively in respect to the rights of the parties, the modes of transfer and the solemnities which accompany them. ... In this respect, counsel cites the following passage from the Corporate Management Tax Conference 1989: “ Creative Tax Planning for Real Estate Transactions — Beyond Tax Reform and Into the 1990s" (Canadian Tax Foundation, 1989), at page 8:1: Although a bare trust is not defined in the Income Tax Act, Revenue Canada generally views this to be a trust under common law where the trustee has no significant powers or responsibilities, and can take no action regarding the property held by the trust without instructions from the settlor. ...
TCC
Agpro Services Inc. v. M.N.R., docket 96-136-CPP
Reasons for Judgment Margeson, J.T.C.C. [1] On September 20, 1996 the Minister of National Revenue (the "Minister") made a decision denying the Appellant's request for refund of certain Canada Pension Plan (" CPP ") contributions as an employer. ... She also enclosed a form entitled "How to Appeal to the Tax Court of Canada ". ... Counsel's position was that the matter was not properly before the Court under Section 28 of the Canada Pension, Old Age Security Act (the " Act "). ...
TCC
Te'mexw Treaty Association v. M.N.R., docket 1999-5012-EI
Then, at the bottom of page 6, Vanden Berg- according to the minutes- stated: "... contractors are only paid for work. ... Vanden Berg operates through a corporation, Vanden Berg & Associates Inc. ... In the within appeal, Ardyth Cooper's attitude was borne out by the comment that " if it ain't broke don't fix it". ...
TCC
Larose v. MNR, 92 DTC 2055, [1992] 2 CTC 2339, [1992] 1 CTC 2667
Accordingly, the first argument of counsel for the appellant cannot be allowed. * 4.03.7(2) The judgment nullifying the sale rendered by Mercure, J. in April 1990 certainly cannot affect the rights that the respondent acquired as a result of the sale of the buildings in 1979. ... Such conclusions would also deprive of any relevance a determination of the extent of the rights transferred by the appellant by means of the sale of December 31, 1979. 4.03.10 Thus, the concepts of “legal ownership" and “ beneficial ownership", need it be recalled, are not germane to the property rights regime contained in the Civil Code. ... In this respect, the English version of subsection 248(3) (paragraph 4.03.2) clearly establishes that the concept of “ beneficial ownership” is closely bound up with the abusus held in respect of a property, which is to say the right to dispose of the property as the holder sees fit. ...
TCC
Amway of Canada Limited v. Her Majesty the Queen, [1995] 2 CTC 2488, 96 DTC 1237
The "total alleged forfeiture" figures differ slightly from the totals of the 1980 claims mentioned above in paragraph 4 but the difference is immaterial and it was agreed that the figures in "total alleged forfeiture" are correct with one minor exception as follows: The total of the duty short paid and sales tax short paid ($11,872,036 + $9,067,310.66) is $20,939,347.38. ... As to the effect of the remission order, respondent refers to Canadian Law of Customs and Excise, Eaton & Chalmers, 1968, page 29, where it is stated: In ascertained value forfeiture cases the claimant may seek to raise some question as to the accuracy of the valuation relied upon by the department. ... Therefore the proportion of the $37,117,903 representing duties and taxes 1s: 20,943.612 x $37,117,903 == $7,387,127.57 105,234,809 This amount of $7,387,127.57 settled duties and taxes for the years ending August 31, 1974 through August 31, 1980. ...
TCC
Blandine Girard L’hérault and Alain L’hérault v. Minister of National Revenue, [1993] 2 CTC 2612, 93 DTC 1108
The year 1985 concerns the sale of a property located on 13th avenue in Charny, Quebec (the “ Charny property"). ... Girard L'Hérault for 1985 and 1987 are contained in paragraphs 5 (a) to (z) of the reply to the notice of appeal, which reads as follows: (a) On March 2 1983, the appellant bought as undivided co-owner property located on 13th avenue, Charny (the “ Charny property"); (b) the Charny property was held by the following persons in the following proportions: Gaétane Delisle 50 per cent Alain L’Hérault 25 per cent Blandine Girard-L’Hérault 25 per cent (c) Alain L’Hérault is the appellant’s husband; (d) Gaétane Delisle is a real estate agent who has worked in real estate since 1982; (e) the appellant is familiar with Gaétane Delisle’s expertise in real estate; (f) Alain L'Hérault has worked as an electrician for Gilles Morin, a real estate broker, who later became the husband of Gaétane Delisle; (g) Gilles Morin himself referred Gaétane Delisle to the appellant and her husband; (h) Gilles Morin acted as real estate agent when the Charny property was bought; (i) Gilles Morin also acted as real estate agent at the time the Charny property was disposed of; (j) the Charny property was sold on Januar 10, 1985, after being held for only 22 months; (k) the profit made by the appellant on disposing of the property breaks down as follows: proceeds of disposition: $117,000 purchase cost: 94,472 capital gain: $ 22,528 appellant's share (25 per cent): $ 5,632 (l) the appellant and the other co-owners purchased the Charny property to resell it at a profit and with the intention of carrying on a business; (m) during the 1987 taxation year, the appellant participated in the profits and losses of a partnership known as “LES HABITATIONS CHARLESBOURG ENR.” ... (hereinafter"the company”); (p) the shareholders and the directors in the company were Gilles Morin and Denis Lacombe, both real estate brokers; (q) Gilles Morin and Denis Lacombe are both partners in the aforementioned partnership; (r) the partnership purchased three properties on May 20, 1986 through Gilles Morin, who acted as real estate broker; (s) on October 19, 1987, seventeen months after their purchase, the partnership received a purchase offer for the three properties through Gilles Morin; (t) on October 22, 1987 the purchase offer was accepted by the partnership and the three properties sold by notarial instrument on December 1, 1987; (u) Gilles Morin saw to the sale of the properties and acted as agent in this respect with the partnership; (v) in disposing of the three properties, the partnership declared a capital gain of $517,683, calculated as follows: selling price: $2,932,019 purchase price: $2,360,886 commission: 53,450 2,414,336 $ 517,683 (w) the appellant holds a share in the partnership with a fraction of 12/192; (x) the appellant reported $32,355 as a capital gain, that is 12/192 of $517,683; (y) the appellant claimed a capital gains deduction of $10,478.45 on the taxable capital gain of $15,635 thus reported by the appellant; (z) the appellant and the other partners purchased the three properties to resell them at a profit and with the intention of carrying on a business; [Translation.] ...
TCC
Cassidy's Limited (Formerly Packer Floor Coverings Ltd.) v. Minister of National Revenue, [1990] 1 CTC 2043
Evans & Co. Ltd. v. Commissioner of Inland Revenue, [1976] 1 N.Z.L.R. 425. ... I adopt the comment of the High Court of Australia in Charles Moore & Co (WA) Pty Ltd. v. ... Milne, Whiteman and Wheatcroft On Income Tax, second edition, Street & Maxwell, London, 1976. ...
TCC
145101 Canada Limited (Formerly Beacon Hill Lodges of Canada Ltd.) v. Minister or National Revenue, [1989] 2 CTC 2418, 89 DTC 644
Graeme Stamp, Vancouver Manager of the Industrial-Commercial Properties Division of Imperial, from Grover, Elliott & Co. ... This compares with the first six month period in 1979 of $605,339.00 — an increase of $388,743.00. ... O & M Investments Ltd. v. M.N.R., [1985] 2 C.T.C. 2207; 85 D.T.C. 536 at page 2209 (D.T.C. 537) (T.C.C.) ...
TCC
Jean-René Clément v. Minister of National Revenue, [1989] 1 CTC 2010, 88 DTC 1751
The stable was even enlarged (Exhibit A-9:1 — photo) to make room for more horses. 3.09 The 1980-83 recession also affected horse breeders, including the appellant and his tenants. ... Clément had told him to go, since it was more representative of the maple grove. 3.23 A study by the forestry engineers Demers & Dumoulin on the cultivation of Christmas trees (Exhibit A-5) indicates at page 28 that spruces are sold as Christmas trees. 3.24 Finally, with respect to the 1,000 cords of wood, the appellant submits that he makes a profit of about $7 a cord. 3.25 Concerning the time Mr. ... Law — Cases- Analysis 4.01 Law The major provisions of the Income Tax Act that are involved in this case are paragraph 12(1)(g) and subsection 31(1). ...