Search - 江西农大 毛瑢

For those involved this means a taxable benefit in 1981 of $0.625 per share ($24.125 — 23.50 = 0.625) and a new cost base of $24.125. ... For those involved this means a taxable benefit in 1981 of $1.90 per share ($25.75 — $23.85 1.90) and a new cost base of $25.75. ... Gish Vice-President & Secretary Mr. Lovig also identified other memoranda from Mr. ...

In addition, the estate claimed as a business loss, a decline in the value of the land from 1981 to 1984: Inventory adjustment (calculated in accordance with paragraph 9 of information Bulletin 102R Deemed proceeds of property at date of death at estimated fair market value 165,000^ Cost of property 1,057,412 [3] Loss before notional capital gain 892,412 Notional taxable capital gain Notional proceeds, March 1/81 $ 909,600 Adjusted cost base (18,672) Notional capital gain $ 890,928 Notional taxable capital gain 445^.464 Loss on inventory 948 The estate also requested that the resulting loss be carried back in respect of Duthie’s 1981, 1982 and 1983 taxation years. ...

An interest is vested if two requirements are satisfied: (i) the person(s) entitled to it must be ascertained; and (ii) it must be ready to take effect in possession forthwith, and be prevented from doing so only by the existence of some prior interest(s): Megarry and Wade, The Law of Real Property, (London: Stevens & Sons Limited, 1984) pages 231-32. ... For instance, in Oosterhoff & Rayner, Anger & Honsberger on Real Property (2d Ed.) ...

. — Where a taxpayer is liable for the payment of an amount assessed under this Act (in this subsection referred to as the “unpaid amount"), other than an amount payable under subsection 227(9), the Minister shall not, for the purpose of collecting the unpaid amount, (a) commence legal proceedings in a court, (b) certify the unpaid amount under section 223(1), (c) require a person to make a payment under subsection 224(1), (d) require an institution or person to make a payment under subsection 224(1.1), (e) require the retention of the unpaid amount by way of deduction or set-off under section 224.1, (f) require a person to turn over moneys under subsection 224.3(1), or (g) give a notice, issue a certificate or make a direction under subsection 225(1) before the day that is 90 days after the day of mailing of the notice of assessment. ... The Evidence When the order of November 28, 1988 was granted, as noted in the order itself, affidavits were on file, all dated November 25, of Sherman Lee, Director — Taxation of the Hamilton District Office of the Department of National Revenue — Taxation, and from the same office, of Nancy Olexiuk, Collections Officer, of George Rennick, Collections Officer and of Joseph Gial- lanardo, Business Auditor. ...

Canada (sub nom Coopers & Lybrand Ltd. v. Canada, [1994] 2 C.T.C. 2244, 94 D.T.C. 6541 (F.C.A.). ... Cases referred to: James Richardson & Sons, Ltd. v. M.N.R., [1984] 1 S.C.R. 614, [1984] C.T.C. 344, 84 D.T.C. 6325; R. v. ... He relies primarily on James Richardson & Sons, Ltd. v. M.N.R., [1984] 1 S.C.R. 614, [1984] C.T.C. 344, 84 D.T.C. 6325, and R. v. ...

By deed dated June 1, 1955 appellant acquired from Bowater’s Newfoundland Pulp & Paper Mills Limited (also a wholly-owned subsidiary of The Bowater Corporation of North America Limited) rights relating to Corner Brook and the Humber River in Newfoundland, hereafter called the Corner Brook rights and the Humber River rights. ... There was some problem with the Department of Fisheries on this — if the diversion went ahead they would want us to make provisions for the salmon that run up that river. ... Meg g ary & Wade, at page 606: “‘Demise is a technical term for let or lease, thus a lease may be referred to as a demise.” 5 F3.... ...

From 1961 to 1962 he taught at William & Mary University in Norfolk, Virginia. ... Unless you have some objection, we might prefer to complete our purchase by two distinct transactions, namely — pay $116,212.75 for the debt and pay the balance of the purchase price for the shares. ... The Appellant in its Notice of Appeal has now alleged that the portion of the loss attributable to the gaining or producing of income should be computed by first deducting the fixed expenses of the vessel and then applying to the variable expenses only (eg crew wages, fuel & galley) the ratio that personal use bore to total use of the vessel. ...

Traditionally, the residence of the debtor- the person paying the income — was of primary importance. ... These connecting factors — the residence of the debtor and the residence of the person the employment — point to the reserve. ...

The plaintiff alleges instead that there was a“ " verbal agreement" meaning, apparently, a common understanding which had never even been fully articulated orally between the parties. ...

I set out the statutory meaning of ‘ principal residence”: 54. (g) ‘principal residence” of a taxpayer for a taxation year means a housing unit. a leasehold interest therein. or a share of the capital stock of a co-operative housing corporation. owned, whether jointly with another person or otherwise. in the year by the taxpayer. if the housing was. or if the share was acquired for the sole purpose of acquiring the right to inhabit a housing unit owned by the corporation that was, (1) ordinarily inhabited in the year by the taxpayer, his spouse or former spouse, or a child of the taxpayer who, during the year, was wholly dependent upon him for support and was a person described in subparagraph 109(1)(d)(i), (ii) or (iii), or (ii) property in respect of which the taxpayer has made an election for the year in accordance with subsection 45(2). except that. subject to section 54.1. in no case shall any such housing unit. interest or share. as the case may be, be considered to be a taxpayer's principal residence for a year (iii) unless it has been designated by him in prescribed manner to be his principal residence for that year and no other property has been so designated by him for that year, or (iv) by virtue of subparagraph (ii). if by virtue of that subparagraph the property would, but for this subparagraph. have been his principal residence for four or more previous taxation years. and for the purposes of this paragraph the “principal residence” of a taxpayer for a taxation year shall be deemed to include. except where the property consists of a share of the capital stock of a co-operative housing corporation, the land subjacent to the housing unit and such portion of any immediately contiguous land as may reasonably be regarded as contributing to the taxpayers use and enjoyment of the housing unit as a residence. except that where the total area of the subjacent land and of that portion exceeds one acre. the excess shall be deemed not to have contributed to the individual's use and enjoyment of the housing unit as a residence unless the taxpayer establishes that it was necessary to such use and enjoyment; While the building was not quite a duplex in its construction, it served, to my mind, the same practical function. ...