Search - 报销 发票日期 消费日期不一致

Kathryn Barnard, Revisor [1]               A.G. of Canada v. Kaur, 167 N.R. 98. ...

Reasons for Judgment Lamarre Proulx, J.T.C.C. [1] This appeal concerns the credit for a severe and prolonged physical impairment provided for in section 118.3 of the Income Tax Act (“the Act ”). [2] The impairment is caused by cystic fibrosis, which both of the appellant’s children have. ...

In so reassessing the Appellant, the Minister relied on, inter alia, the facts admitted above and the following assumptions: (a) the Appellant began operating the Activity in March, 1990; (b) the Appellant does not plan any material changes to the Activity in the near future; (c) the Appellant has no previous training or experience in the Activity; (d) at all material times the Appellant was employed on a full time basis as a teacher; (e) before starting the Activity, the Appellant prepared no business plan to determine if it would be profitable; (f) there are no major start up costs associated with this Activity; (g) there are no lease agreements or major capital expenditures required with this Activity; (h) from 1990 to 1995 the Appellant reported the following losses from the Activity, respectively as business losses: Taxation Year Gross Income Net Loss 1990 $ 325 ($4,649) 1991 $109,166 ($8,558) 1992 $261,637 ($5,312) 1993 $168,130 ($12,205) 1994 $145,174 ($14,358) 1995 $148,337 ($16,830) (i) the gross income amounts as outlined in paragraph 8(h) above, include sales and performance bonuses and tool rebates, a portion of which are paid to others; (j) revised to account for the bonuses and rebates paid out, the profit and loss statements of the Activity, including adjusted gross profit, for 1993 and 1994 are summarized as follows: 1993 1994 Sales $142,294.23 $108,648.58 Performance bonuses 25,836.74 36,526.29 Gross Income 168,130.97 147,174.87 Less: Cost of goods sold $143,463.04 $112,015.58 Bonuses paid $9,586.29 21,670.77 GROSS PROFIT: $15,081.64 $11,488.52 Operating expenses: 27,286.69 25,847.26 Net Loss $(12,205.05) $(14,358.74) (k) the Appellant did not have a reasonable expectation of profit from the Activity during the 1993 and 1994 taxation years; (l) the expenses of the Appellant in respect of the Activity were not made nor incurred for the purpose of gaining or producing income from a business or property; and (m) the expenses claimed in relation to the Activity were personal or living expenses of the Appellant. 9. ...

Justice McKenzie's order of December 5, 1994 are deductible by him under paragraph 60(c) of the Income Tax Act which in 1993 and 1994 permitted a deduction as follows: (c) maintenance — an amount paid by the taxpayer in the year as an allowance payable on a periodic basis for the maintenance of the recipient, children of the recipient or both the recipient and the children, if (i) at the time the amount was paid and throughout the remainder of the year the taxpayer was living separate and apart from the recipient, (ii) the taxpayer is the natural parent of a child of the recipient, and (iii) the amount was received under an order made by a competent tribunal in accordance with the laws of a province. [11] He contends further that Mr. ...

I also note that the advertisement the appellant purported to have published in the local newspaper for this business only refers to "amateur, commercial and digital communications – sales, service, consulting". ...

According to Investissement et financement immobilier — Outils d’analyse et d’évaluation by Dominique Achour, when capital gains and inflation are no longer factors to be considered, the focus must be on the cash flow mathematics in order to determine the wise choice for the taxpayer; 8. ...

Whether a teacher receives one-twelfth of his annual salary at the end of each month of the year, one-tenth at the end of each of 10 months of the year, or, as in Alberta, one-twelfth at the end of each of nine months and three-twelfths at the end of a 10 th month, if his contract of service continues throughout the year, there has been no "lay-off" or "separation form... employment" giving rise to an "... interruption... in... earnings" and he is receiving his "usual remuneration"; and I do not, therefore, conceive of the circumstances in which s. 158, or some similar provision, is necessary to avoid payment of unemployment benefits to teachers who are not out of work in the ordinary acceptation of that expression. [20] Petts is cited with approval in the Supreme Court of Canada decision in Dick et al. v. ...

., docket 2000-2476-EI Date: 20001101 Dockets: 2000-2476-EI; 2000-2477-EI BETWEEN: ANDRÉ JAILLET, JACQUES JAILLET, Appellants, and THE MINISTER OF NATIONAL REVENUE, Respondent, Reasons for Judgment Somers, D.J.T.C.C. [1] These appeals were heard on common evidence at Moncton, New Brunswick, on October 4, 2000. [2] The appellants have instituted appeals from the decisions by the Minister of National Revenue (the "Minister") according to which the employment held with J & S Lumber Co. ...

The first question which I must answer, therefore, is whether the Minister has satisfied the onus of showing, under subparagraph 152(4) (a) (i) of the Income Tax Act, that the Appellants have "... made any misrepresentation that is attributable to neglect, carelessness or wilful default... in supplying any information", which in this case specifically means in filing the returns that they have filed. [6] The evidence before me with respect to that is principally the evidence of the two Appellants, which, insofar as the returns for the statute-barred years are concerned, is, as I have said, that they withdrew substantial amounts of cash, probably averaging $400 per week throughout the year, occasionally more, occasionally less. ...

They were supplied by the firm Morel & Frères. Act- analysis [29] In making her assessments, the respondent relied on ss. 3, 5(1) and 163(2) of the Act. [30]There are limits to the well-settled rule that the taxpayer has the burden of proof. [31] In the instant case the respondent had all the cheques available, both those establishing the moonlighting and those showing the reimbursements of expenses. ...