Search - 报销 发票日期 消费日期不一致

G & J Muirhead Holdings Ltd. v. The Queen, 2014 DTC 1067 [at at 3009], 2014 TCC 49 (Informal Procedure)-- summary under Personal Services Business Summary Under Tax Topics- Income Tax Act- Section 125- Subsection 125(7)- Personal Services Business intentions in services contract are irrelevant; overtime rates The taxpayer was owned by its sole employee ("Muirhead") and his wife, and provided well inspection services to an arm's length corporation ("Harvest") under a services contract with it. The taxpayer had a personal services business – but for the services contract, Muirhead would have been a Harvest employee. ...

Minister of Finance, 2008 CanLII 15226 (Ont SCJ), briefly aff'd 2009 ONCA 715-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission A transfer of tangible personal property by an Ontario corporation ("1006") to a second corporation ("QL") would have been exempt from Ontario retail sales tax if QL were a wholly-owned subsidiary of 1006 at the time of the transfer. ...

The Queen, 2011 DTC 1117 [at at 628], 2011 TCC 148, aff'd 2012 DTC 5138 [at 7292], 2012 FCA 214 supra-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt no implied set-off The taxpayer acquired a 100% undivided interest in a property (the "Quarter Claim") adjoining its "Golden Giant" mine subject to a 50% net profits royalty in favour of the vendor ("Teck/Corona"). ...

Commissioners for HM Revenue and Customs, [2013] UKSC 26, [2013] WLR (D) 172-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission mistake re tax consequences justified rescinding settlement of trust The claimant had settled the moneys received as damages for injury to her husband on a discretionary trust of which she and others were trustees. ...

Canada, 2012 DTC 5031 [at at 6682], 2011 FCA 355-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development The taxpayer, a producer of plastic containers, undertook a project to "improve the existing product to make it a smaller and significantly lighter storage system" (para. 9 of Statement of Appeal, quoted at para. 5). ...

The Queen, 2013 DTC 1008 [at at 54], 2012 TCC 376 (Informal Procedure)-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development The taxpayer, which installed heating, air conditioning and ventilation systems in residential homes, claimed SR&ED credits relating to its "High Static High Velocity Fan Coil System Development" project. ...

., 97 DTC 5252, [1997] 2 CTC 286 (FCA)-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission retroactive effect of nunc pro tunc rectification order The taxpayers neglected to have shares that purportedly were issued to them in 1985 added to the authorized capital of the issuing corporation. ...

The Queen, 2015 DTC 1212 [at at 1366], 2015 TCC 263-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development new knowledge required to adapt software to poor local infrastructure The taxpayer had to adapt its existing system for implementing a nation-wide health information system in Belize given the severe telecommunications and internet connectivity issues there. ...

A.G. of Canada, 2015 ONSC 6245-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission reorganization of corporate structure to reflect what it was thought to be at the time of making a tax election The Telus group had a tiered partnership structure. ...

Re Razzaq Holdings Ltd (2000), 11 BLR (3d) 157, 2000 BCSC 1829-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission In 1992 the two shareholders of a corporation purported to transfer a total of 100 Class A shares and 100 Class B shares equally to two holding companies. ...