Search - 深圳居住证 办理条件 最新政策

Graham J accepted the submission of the applicants (the designated partners of the partnerships) in connection with a Rule 58 determination that the Minister could not issue a valid Notice of Determination if the Minister had concluded that the partnership in question did not exist – so that the Notices of Determination were invalid. ...

The corporation then sold this middle lot to an individual purchaser coupled with a covenant that it would demolish this structure – which, however, it did not do until 45 days after closing. ...

The corporation then sold this middle lot to an individual purchaser couple with a covenant that it would demolish this structure – which, however, it did not do until 45 days after closing. ...

. … The argument put forward by Bowman that they are “nothings” for Canadian tax purposes because they are merely reputational payments arising in a non-business circumstance may ultimately be upheld by the Tax Court, but it is not so clear at this stage as to render the CRA’s position unreasonable. ...

. … Moreover, the Tribunals looked to the substantive matters rather than theoretical factors, such as causative link and governing law, and so applied a practical approach. ...

(f) of the ECP definition for “the cost of … a right to acquire [a share]” did not apply given that “the word ‘cost’ contemplates an acquisition of an asset or other property” (para. 103), whereas “when a stock option is surrendered to the issuing corporation, the rights represented by that option [instead] are extinguished” (para. 122). ...

(f) of the ECP definition for “the cost of … a right to acquire [a share]” did not apply given that “the word ‘cost’ contemplates an acquisition of an asset or other property” (para. 103), whereas “when a stock option is surrendered to the issuing corporation, the rights represented by that option [instead] are extinguished” (para. 122). ...

Agence du revenu du Québec, 2018 QCCQ 5692, aff'd 2020 QCCA 1496-- summary under Subsection 245(4) Summary Under Tax Topics- Income Tax Act- Section 245- Subsection 245(4) no abuse where individuals used PUC thrust upon them by an arm’s length investor (through PUC averaging) to subsequently strip surplus When the taxpayers’ corporation (“Opco”), a small business corporation, was in financial difficulty, a Quebec regional development fund agreed to inject equity capital in Opco on terms dictated by the fund – which entailed the fund investing in the common shares of Opco, so that the paid-up capital of the taxpayers’ shares was stepped-up from a nominal amount to $1.45 million (as a result of the aggregate class PUC being averaged on a per share basis). ...

In rejecting a Crown submission that the taxpayer was precluded from submitting that it was a s. 2(c) bank or used the equivalent of more than five full time employees, C Miller J stated (at para. 184) that the purpose of the s. 165(1.11) rule is that “the Minister knows the nature of the dispute and the quantum of tax at issue” (para. 184), that the Crown was requiring him to “look into the minutia of what is meant by a reasonable description of an issue” (para. 187), that the Crown “knew full well that there would be considerable evidence as to what GBL did … which encompasses activities that might constitute the provision of financial services (part of the Bank Act, subsection (2(c)) definition” (para. 190) and that “whether there was the equivalent of five full-time employees is subsumed into the employee issue generally” (para. 190). ...

Such an interpretation would clearly undermine the intent of the Parliament …. ...