Search - 江西农大 毛瑢

He gave us an example, Exhibit D-1, an invoice from Lep Interational wherein the item “Droits et Taxes/Duty & Taxes” are on the same line and he thus would not know if taxes were or were not paid. ... No other invoices were filed into the record and I cannot say that if the sales tax were not paid, the invoice issued by Lep International would still read “Droit et Taxes/Duty & Taxes” or only “Droits/Duty.” ...

Analysis The relevant provisions of the Income Tax Act are as follows: Section 18: General limitations. (1) In computing the income of a taxpayer from a business or property no deduction shall be made in respect of (a) General limitation — an outlay or expense except to the extent that it was made or incurred by the taxpayer for the purpose of gaining or producing income from the business or property; Section 20: Deduction permitted in computing income from business or property. (1) Notwithstanding paragraphs 18(1)(a), (b) and (A), in computing a taxpayer’s income for a taxation year from a business or property, there may be deducted such of the following amounts as are wholly applicable to that source or such part of the following amounts as may be regarded as applicable thereto: (c) Interest — an amount paid in the year or payable in respect of the year (depending upon the method regularly followed by the taxpayer in computing his income), pursuant to a legal obligation to pay interest on (i) borrowed money used for the purpose of earning income from a business or property (other than borrowed money used to acquire property the income from which would be exempt or as acquire a life insurance policy), (ii) an amount payable for property acquired for the purpose of gaining or producing income therefrom or for the purpose of gaining or producing income from a business (other than property the income from which would be exempt or property that is an interest in a life insurance policy), (3) Idem. ...

ZUCAWICH: Right, he filed a net worth statement and Revenue Canada’s--- THE COURT: — and then Judge Goetz gave his decision. ... THE COURT: This Court is prepared to pronounce judgment, or an order at least in relation to Her Majesty the Queen’s notice for an order dismissing the appellant’s action T-2768-91 with costs. *** The statement of claim in this action was filed in the Federal Court in Winnipeg on November 1st, 1991. ...

In the late summer of 1965 a firm of mining engineers and consultants, A C A Howe & Associates Limited (hereinafter called the “Howe Company”), also of Toronto and which had been known to the appellant since 1958, was handling a drilling programme for him on a mining property in New Brunswick owned by one of the companies which he controlled. ... Yours sincerely, A C A HOWE & ASSOCIATES LTD (sgd) A C A Howe A CA A Howe, P Eng. ...

The money for construction included $151,000 obtained on a mortgage from Western Canada Savings & Loan Company in July 1965, $20,000 obtained from one Maddock on a second mortgage, $10,000 on another mortgage (Oak), and several small personal loans. ... When Robinson first proposed that they sell the property they were not interested, but the problems continued and by the latter part of 1967 she felt that she could not continue to face them, she discussed the situation with her husband, and when Robinson came back later they decided to see whether a satisfactory sale could be arranged — and the sale to Vyburin eventually resulted. ...

I shall later deal, as well, with that point. 3 The issue in respect of all three years is identical: whether the plaintiff was “... resident in Canada at any time in the year”. ... If he did in fact dispose of the company's assets “... he shall secure the Petitioner for the maintenance payments...”. 10 Mrs Erikson, following the divorce, continued to reside with the two boys in Edmonton. ...

Standard of review [11] It is well understood that the standard of review applicable in this case is the reasonableness standard (He v Canada (Attorney General), 2022 FC 1503 [He] at paragraph 20; Lajoie v Canada (Attorney General), 2022 FC 1088 at paragraph 12; Aryan at paragraphs 15 – ‍16). [12] Where the applicable standard of review is reasonableness, the role of a reviewing court is to examine the reasons given by the administrative decision maker and determine whether the decision is based on “an internally coherent and rational chain of analysis” that is “justified in relation to the facts and law that constrain the decision maker” Canada (Minister of Citizenship and Immigration) v Vavilov, 2019 SCC 65 [Vavilov] at paragraph 85. ... DATED: December 22, 2022 APPEARANCES: Louise Labrosse FOR THE APPLICANT ON HER OWN BEHALF Anna Kirk FOR THE RESPONDENT SOLICITORS OF RECORD: Attorney General of Canada Montréal, Quebec FOR THE RESPONDENT   ...

Jean-Eudes Tremblay (signature) Marie-Claude Tremblay (signature) Witness To complete paragraph 2 of the said“ Letter of Agreement", the plaintiff also produced, as Exhibit P-5, a handwritten document entitled ” Notes for the file”, dated June 17, 1987, and signed by Marie-Claude Tremblay, the defendant's daughter, which included the following text: [Translation] I hereby acknowledge that Métal Moderne Chicoutimi Ltée has tried to clear up its liability of $14,165.95 (so far) to Revenue Canada, Taxation, by selling its assets to Jean-Eudes Tremblay by block sale, and the same was true during the block sale by Jean-Eudes Tremblay to Industrie Moc Inc. ... As for the witness Marie-Claude Tremblay, she acknowledged that she had signed the " Letter of Agreement" (Exhibit P-4) and the supplementary document (Exhibit P-5), although she explained that she had not read the documents before signing. ...

Avery Jones, “Nothing Either Good or Bad, But Thinking Makes It So — The Mental Element in Anti-Avoidance Legislation” (1983) British Tax Review 9. ... More is to be gained by examining the second of the two requirements — reasonable expectation of profit. ... R., [1996] 1 S.C.R. 305, [1996] 1 C.T.C. 290, 96 D.T.C. 6121 at page 316 (C.T.C. 298, D.T.C. 6125); see also Dickson C.J. in Bronfman Trust, supra, at page 45 (C.T.C. 124, D.T.C. 5064). 9 See also Herald & Weekly Times Ltd., Re (Herald & Weekly Times Ltd. v. ...

According to Schedule 1 attached to the notice of assessment, that figure was arrived at as follows: Sale of land $2,307,330.00 Cost of land in 1960 $393,666.00 Capitalized carrying charges — 1960 to 1972 148,257.00 $ 541,923.00 1972 taxable income $1,765,407.00 Counsel for the plaintiff took two broad positions: (1) that the plaintiff’s dealing with the realty was not an adventure in the nature of trade, the submission being that it was acquired as an investment which resulted in a capital gain; (2) that the plaintiff was neither a resident of Canada nor a nonresident which carried on business in Canada and so was not taxable. ...