Search - 报销 发票日期 消费日期不一致
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Decision summary
Galea v The Assessment Review Committee & Anor (Mauritius), [2025] UKPC 17 -- summary under Business Source/Reasonable Expectation of Profit
Galea v The Assessment Review Committee & Anor (Mauritius), [2025] UKPC 17-- summary under Business Source/Reasonable Expectation of Profit Summary Under Tax Topics- Income Tax Act- Section 3- Paragraph 3(a)- Business Source/Reasonable Expectation of Profit whether an activity qualifies as “carried on with a view to profit" turns on the taxpayer’s subjective intention Whether the taxpayer could deduct his 92% share of the losses incurred by a Mauritius partnership (of which he was the dominant partner) from his other sources of income turned on whether the partnership was carrying on a “business,” whose definition in the Mauritian Income Tax Act 1995 relevantly referred to "any trade, profession, vocation or occupation, manufacture or undertaking, or any other income earning activity, carried on with a view to profit. ...
Decision summary
Taiga Building Products Ltd. v. Deloitte & Touche, LLP, 2014 DTC 5082 [at at 7068], 2014 BCSC 1083 -- summary under Negligence, Fiduciary Duty and Fault
Deloitte & Touche, LLP, 2014 DTC 5082 [at at 7068], 2014 BCSC 1083-- summary under Negligence, Fiduciary Duty and Fault Summary Under Tax Topics- General Concepts- Negligence, Fiduciary Duty and Fault tax contingency fee to auditors did not engage conflict of interest; internal memo not relevant to actual advice The defendant ("D&T"), which was the auditor of the plaintiff (Taiga), recommended that Taiga adopt a plan to minimize provincial taxes, relying on a "loop hole" in the Corporations Tax Act (Ontario), which permitted interest paid to an affiliate incorporaated outside Canada but which was resident in Canada to be received by it free of Ontario corporate tax. ...
Decision summary
London & Thames Haven Oil Wharves, Ltd. v. Attwooll (1966), 43 TC 491 (CA) -- summary under Compensation Payments
London & Thames Haven Oil Wharves, Ltd. v. Attwooll (1966), 43 TC 491 (CA)-- summary under Compensation Payments Summary Under Tax Topics- Income Tax Act- Section 9- Compensation Payments The taxpayer, which operated an oil storage installation that was supplied by tankers, suffered damage to a jetty through the negligent handling of a tanker by a third party. ...
Decision summary
G E Financial Investments v.The Commissioners for Her Majesty's Revenue & Customs, [2021] UKFTT 0210 (Tax Chamber), ultimately aff'd [2024] EWCA Civ 797 -- summary under Article 5
G E Financial Investments v.The Commissioners for Her Majesty's Revenue & Customs, [2021] UKFTT 0210 (Tax Chamber), ultimately aff'd [2024] EWCA Civ 797-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 somewhat isolated (albeit in large amounts) loan activity in US did not represent a business under UK concepts and therefore did not entail a US PE under the UK-US Treaty A US company (“GEFI Inc.”) and UK company (“GEFI”) in the GE group formed a Delaware LP (“LP”) with GEFI Inc. as the 1% general partner and GEFI as the 99% limited partner. ...
TCC (summary)
D & D Livestock Ltd. v. The Queen, 2013 DTC 1251 [at at 1412], 2013 TCC 318 -- summary under Subsection 55(2)
D & D Livestock Ltd. v. The Queen, 2013 DTC 1251 [at at 1412], 2013 TCC 318-- summary under Subsection 55(2) Summary Under Tax Topics- Income Tax Act- Section 55- Subsection 55(2) stock dividend by dividend payer did not reduce the safe income attributable to its subsidiary After a preliminary reorganization, all of the shares of the taxpayer (consisting of Class A common shares and Class D preference shares) were owned by another Canadian corporation ("HLL"), whose safe income on hand ("SIOH") respecting the taxpayer was $1.493M, comprised of safe income earned by the taxpayer of $0.976M and safe income of $0.517M in respect of the taxpayer's 50% shareholding of another Canadian corporation ("RTI"). ...
News of Note post
In fact, another public company (“Inco” – the 25% minority shareholder) made a subsequent offer that was accepted by DFR, thereby triggering the payment by it of the break fee. ... Falconbridge was carrying on its business when it negotiated the Merger … Agreement[s], … which provided for the fees in dispute. … The … Fees were ancillary business income received by Falconbridge in the course of earning income from business. ... The Queen, 2021 TCC 63 under s. 9 – compensation payments. ...
News of Note post
31 January 2021- 11:01pm Prairies Tubulars – Federal Court finds that requiring payment of duties before they could be appealed was not unconstitutional Email this Content Prairies Tubulars challenged the constitutionality of provisions of the Special Import Measures Act (the “Appeal Payment Provisions”) which required it to pay all outstanding duties before proceeding with the SIMA’s appeal procedure. ... Before dismissing the application, Ahmed J stated: [L]egislation may be inconsistent with section 96 … if it creates financial obstacles that impose undue hardship on potential litigants …. However, in light of the Applicant’s gross earnings … I am not persuaded … that the Appeal Payment Provisions cause it undue hardship. … Trial Lawyers is distinguishable … because the Appeal Payment Provisions are remedial, not punitive. ...
Technical Interpretation - Internal summary
15 January 2007 Internal T.I. 2006-0216801I7 - Redemption of US $ Denominated Shares -- summary under Subsection 39(2)
15 January 2007 Internal T.I. 2006-0216801I7- Redemption of US $ Denominated Shares-- summary under Subsection 39(2) Summary Under Tax Topics- Income Tax Act- Section 39- Subsection 39(2) s. 39(2) application on USD pref redemption, cf. if USD common shares The redemption of U.S. ... However, the Directorate noted its previous comments that MacMillan Bloedel “ deals with the redemption of redeemable and retractable preferred shares, which may be viewed as similar to the repayment of a debt obligation” and it is “not prepared to extend the reasoning to a redemption of shares in general.” ...
Technical Interpretation - Internal summary
18 May 2022 Internal T.I. 2018-0788761I7 F - Amortissement – Travaux sur un bien loué et F&T -- summary under Subsection 1102(4)
18 May 2022 Internal T.I. 2018-0788761I7 F- Amortissement – Travaux sur un bien loué et F&T-- summary under Subsection 1102(4) Summary Under Tax Topics- Income Tax Regulations- Regulation 1102- Subsection 1102(4) to be improvements or alterations to leasehold interest, property acquisitions must be assimilated to landlord’s property The taxpayer, which subleased premises containing “Shells” consisting essentially of foundations, walls and roofs, installed wall and floor coverings and performed electrical, ventilation and plumbing work to make the premises suitable for use in its manufacturing and processing (“M&P”) operations. ... Regarding whether the costs of such work should be added to the cost of the taxpayer’s Class 13 leasehold interest pursuant to Reg. 1102(4) before regard was had to Reg. 1102(5), CRA stated: [A]n amount expended is for the making of improvements or alterations to a leased property within the meaning of subsection 1102(4) where such expended amount relates to property that is incorporated into the leased property and becomes the property of the lessor. … Generally, the owner of a building owns everything that is joined to the building. ...
Technical Interpretation - Internal summary
18 May 2022 Internal T.I. 2018-0788761I7 F - Amortissement – Travaux sur un bien loué et F&T -- summary under Ownership
18 May 2022 Internal T.I. 2018-0788761I7 F- Amortissement – Travaux sur un bien loué et F&T-- summary under Ownership Summary Under Tax Topics- General Concepts- Ownership leasehold improvements are assimilated to the landlord’s property unless the lease specifies otherwise Before quoting from Mount Robson in this regard, the Directorate indicated that: Generally, the owner of a building owns everything that is joined to the building. ...