Search - 教育部《义务教育课程方案（2023年版）》

Bowker, 2023 FCA 133-- summary under Subsection 152(1) Summary Under Tax Topics- Income Tax Act- Section 152- Subsection 152(1) Galway principle required that a case not be settled on a basis fundamentally at odds with the Minister’s view of the facts and law The taxpayer had a s. 163(2) penalty vacated in the Tax Court on the basis that her involvement in the false amended return filed by her was completely passive. ... Bowker, 2023 FCA 133 under s. 162(7)(b), s. 220(3.1), Statutory interpretation- noscitur a sociis, General concepts – judicial comity and Rule 147(3)(d). ...

The King, 2023 TCC 28-- summary under Person Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Person widow was a "spouse" of her deceased husband Russell J followed Kuchta in finding that, in the context of s. 160(1)(a), a widow was the spouse of her deceased husband. ...

Royal Bank of Canada v Commissioners for His Majesty's Revenue and Customs, [2023] EWCA Civ 695, aff'd [2025] UKSC 2-- summary under Income Tax Conventions Summary Under Tax Topics- Treaties- Income Tax Conventions French version relevant to interpretation Falk LJ was assisted in arriving at a restrictive interpretation of Art. 6 of the Canada-U.K. ...

The Queen, 2022 TCC 91 (Informal Procedure), aff'd 2023 FCA 235-- summary under Subsection 223(1) Summary Under Tax Topics- Excise Tax Act- Section 223- Subsection 223(1) statement that purchase price included HST “if” subject to HST was not an HST-inclusive clause Smith J further found that the appellant’s purchase of a new home did not satisfy the s. 254(2)(d) test that the purchase price included HST, noting that the purchase agreement merely provided that the purchase price included HST “if” the sale was subject to HST. ...

The King, 2023 TCC 54 (Informal Procedure)-- summary under Subsection 223(1) Summary Under Tax Topics- Excise Tax Act- Section 223- Subsection 223(1) price stated to include any HST included HST since the sale was taxable Sommerfeldt J found that a sale of a new home occurred as an adventure in the nature of trade, and was not the sale of a home that had previously been occupied as a residence, so that the HST-inclusive price included tax. ...

Canada, 2023 FCA 195-- summary under Subsection 171(1) Summary Under Tax Topics- Income Tax Act- Section 171- Subsection 171(1) TCC can make a finding of mixed fact and law different from that argued by either party Webb JA found that the Tax Court could make a mixed finding of fact and law (as to the nature of a supply made having regard to the ETA definition of a financial service) that was on a basis different than argued by either party. ...