Search - 报销 发票日期 消费日期不一致

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TCC

Burger King Restaurants of Canada Inc. v. Her Majesty the Queen, [1997] 1 CTC 2058, 97 DTC 841

.: The appellant appeals from assessments of income tax for the 1985, 1986 and 1987 taxation years. ... Design # of times used in Processing area as building restaurants in issue a percentage of total building BK90 11 53.72 BK92 9 38.79 BK22 7 49.16 BKSOXL 4 45.72 BK120 6 56.12 Image 87 [3] 7 45.73 BKSOL 4 49.30 48 Neither counsel suggested that success be divided on the basis that the processing portion of the floor area of some buildings is greater than 50 per cent and of others is less. ...
TCC

Hartnell v. R., [1997] 2 CTC 2005

(“Posi-Line”)) appeals from an assessment of $71,782.25, pursuant to subsection 227.1(1) of the Income Tax Act (the “Acf ’). ... For Stone Laurie & Company to prepare a financial statement for a fiscal year end of August 31, 1989 and noting that it was a change, I would assume that they would have required a resolution of the board of directors, dated sometime prior to August 31, 1989, changing the year end, or they would have in their review engagement report to the shareholders dated November 23, 1989, have brought up the necessity of proper corporate procedures to be carried out to effectively change the corporate fiscal year end. ...
TCC

Johnston v. R., [1997] 2 CTC 3012

NO Severe osteoarthritis of hips requiring replacement. Can your patient walk 100 metres on level ground (1 block) with an aid? ... NO Uses canes but able to walk only sometime (sic). This answer was given on August 28, 1994. ...
TCC

Baynham v. R., [1998] 1 CTC 2579, 98 DTC 1169

. /?.,(! 983), 83 D.T.C. 5388 (Fed. T.D.) at page 5392 indicating that there need only be one transaction so long as the transaction is of the same kind and is carried out in the same way as that of an ordinary trader. ... “Wilful blindness by someone capable of acting in a responsible manner is not a matter of ‘ignorance of the law’ in its jurisprudential sense it can amount to gross negligence in appropriate circumstances.” ...
TCC

Turcotte v. R., [1998] 3 CTC 2359

. the amount, if any, by which (i) the total of all amounts (other than amounts described in paragraph (g), amounts received in the course of business, and amounts received in respect of, in the course of or by virtue of an office or employment) received by the taxpayer in the year, each of which is an amount received by the taxpayer as or on account of a scholarship, fellowship or bursary, or a prize for achievement in a field of endeavour ordinarily carried on by the taxpayer, other than a prescribed prize, exceeds the greater of $500 and the total of all amounts each of which is the lesser of (ii) the amount included under subparagraph (i) for the year in respect of a scholarship, fellowship, bursary or prize that is to be used by the taxpayer in the production of a literary, dramatic, musical or artistic work, and (iii) the total of all amounts each of which is an expense incurred by the taxpayer in the year for the purpose of fulfilling the conditions under which the amount described in subparagraph (ii) was received, other than (A) personal or living expenses of the taxpayer (except expenses in respect of travel, meals and lodging incurred by the taxpayer in the course of fulfilling those conditions and while absent from the taxpayer’s usual place of residence for the period to which the scholarship, fellowship, bursary or prize, as the case may be, relates), (B) expenses for which the taxpayer was reimbursed, and (C) expenses that are otherwise deductible in computing the taxpayer’s income; Section 7700 of the Income Tax Regulations (the “Regulations”) reads as follows: For the purposes of subparagraph 56(1)(n)(i) of the Act, a prescribed prize is any prize that is recognized by the general public and that is awarded for meritorious achievement in the arts, the sciences or service to the public but does not include any amount that can reasonably be regarded as having been received as compensation for services rendered or to be rendered. ... Bruneau, Les principes de l’imposition au Canada, llth ed., Montréal, Wilson and Lafleur 1995, at p. 265. 3 3Supra, note 1, p. 532. 4 [1983] C.T.C. 393 (S.C.C.) 5 $ Supra, note 2, pp. 251-252. 6 (1958), 59 DTC 8 (Can. ...
TCC

Tobias v. R.!, [1999] 2 CTC 2351

Kotick wrote a letter to Revenue Canada (Tab 4 of Exhibit A-1) outlining the fact that since May of 1991 the Appellant had nothing to do with the Corporations and could not get information from Pollack. ... Submissions of the Appellant The Appellant’s Memorandum of Law and Argument states as follows: Appellant’s Memorandum of Law & Argument The issue in these matters is whether the Appellant, as a director of Country Pride Discount Stores Incorporated and Country Pride Leasing Incorporated (the “Corporations”), should be liable for the unremitted employee source deductions of the Corporations, or whether the Appellant is entitled to rely upon the due diligence defence in subsection 227.1(3) of the Income Tax Act, R.S.C. 1985, c. ...
TCC

Martel v. R.|, [1999] 2 CTC 2497, 98 DTC 2012

A document from Martin & Gagnon, Assurances générales, in Alma, was filed as Exhibit A-4. ... As the notarial deeds are proof of their contents in the instant case and establish the transfer of the immovable from the appellant to Les Placements Gaber Inc., the appellant is liable for payment of the $22,215.52 ($1,530.46 + $20,685.06) ([5]) in tax owed by Les Placements Gaber Inc. ...
TCC

Mitchell v. R., [1999] 2 CTC 2721, 99 DTC 750

Those provisions [5] read as follows: 66(12.6) Where a person has given consideration under an agreement to a corporation for the issue of a flow-through share of the corporation and, during the period commencing on the day the agreement was entered into and ending 24 months after the end of the month that included that day, the corporation has incurred Canadian exploration expenses, the corporation may in respect of the share and within that period or within 30 days thereafter, renounce, effective on the date on which the renunciation is made or on such earlier date as may be set out in the form prescribed... to the person in respect of the share... those expenses incurred by it during that period. ... Subsection 66(10.1) in deeming the E renounced by JEC to SC to have been incurred by SC, clearly and simply does just that nothing more and nothing less. ...
TCC

Dr. Kris Rao, Appellant v. The Minister of National Revenue, Respondent, [1999] 2 CTC 2783, 99 DTC 413

. +. No dividends shall be paid in any fiscal year of the Company on the Common Voting Shares and Class “B” Preferred Nonvoting Shares until dividends for the year or period have been declared and paid on the Class “A” Preferred Voting Shares. 5. ... Counsel concluded that these oppression provisions provide the remedy of an aggrieved shareholder for example, a shareholder who did not receive dividends in the priority established by the Articles. ...
TCC

Dias v. The Queen, 2021 TCC 85

Graham” Graham J.   CITATION: 2021 TCC 85 COURT FILE NOS.: 2018-3473(IT)G 2018-3474(IT)G STYLES OF CAUSE: XAVIER DIAS v THE QUEEN WENDY DIAS v THE QUEEN PLACE OF HEARING: Toronto, Ontario DATES OF HEARING: October 19 and 20, 2021 REASONS FOR JUDGMENT BY: The Honourable Justice David E. ... Pniowsky Firm: Thompson Dorfman Sweatman LLP For the Respondent: François Daigle Deputy Attorney General of Canada Ottawa, Canada   ...

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