Search - 深圳居住证 办理条件 最新政策

The appellant’s participation in the three wells, both as to expense sharing and product, was 13 / per cent. ... As the oral equivalent of the symbol (-), as helping to form a negative quantity, e.g. in '-3', ‘-x’, which are read as minus. b. ... For example, it does not contain such words of limitation as “... to an amount up to but not exceeding the taxpayer’s threshold amount,” nor the words “... to the extent that such an amount is not greater than the taxpayer's threshold amount”. ...

This amount was allocated by the agreement as follows: Land $ 662,500 Buildings and other improvements $ 450,000 Personal property including furniture, furnishings, dishes, linen, utensils, and similar equipment $ 12,500 $1,125,000 In assessing the respondent's tax for the year 1976 the Minister accepted this allocation. ... Land $ 662,500 Buildings and other improvements $ 450,000 Personal property including furniture, furnishings, dishes, linen, utensils, and similar equipment $ 12,500 $1,125,000 Both parties, obviously, attached no value to so-called intangibles. ... Muller & Co.’s Margarine Ltd., [1901] A.C. 217 at 223, per Lord Macnaghten, who went on:... ...

Paragraph (e) of subsection 20(1) refers to two kinds of expense deductions — those incurred in the course of issuing or selling capital stock of the taxpayer and those incurred in the course of borrowing money for the purpose of earning income. ... In support of this proposition counsel cited the decision of the Judicial Committee of the Privy Council in Montreal Coke and Manufacturing Co v MNR, [1944] AC 126; [1944] CTC 94; 2 DTC 535 and of the Supreme Court of Canada in Bennett & White Construction Co Ltd v MNR, [1949] S.C.R. 287; [1949] CTC 1; 4 DTC 514. ... Mr Justice Abbott’s warning is thus apt in considering the applicability of the reasoning in the Montreal Coke and the Bennett & White cases in the case at bar particularly because paragraphs 14(a) and (b) and 20(1)(b) relate to deductions for capital expenses. ...

Such an award of costs is ”... normally ordered in respect of the way in which a case has been conducted, not its intrinsic merit. ... Such a basis was disapproved of in the Reading & Bates case, supra. ... The Chief Judge may designate another judge to deal with any application made to the Chief Judge under these Rules. 2 Rule 9(1) reads: 9. (1) Notwithstanding any other provision in these Rules, the Chief Judge may, either on his own motion or on application by an appellant or the respondent if in his opinion special circumstances exist, refer to a panel of three judges designated by him for determination of any question arising out of the application of or pertaining to these Rules. 3 Compare: Reading & Bates Construction Co. v. ...

These dockets were not, and are not, as I see it, " given to the Minister for the purposes of the Income Tax Act”. ... In order to succeed, the appellant had to demonstrate that the documents in question were of a confidential nature within the meaning of subsection 241(1), i.e., that they were: (i) " obtained by or on behalf of the Minister”, (ii) “for the purposes of the Income Tax Act”. ... The most usual and natural meaning of the word " obtained" and of its French equivalent "obtenir", whether read in the context of "any information" as in paragraph 241(1)(a) or in the context of "other document” as in paragraph 241(1)(b), is that of information or document not in the possession of the person seeking either and being "given" to that person. ...

Joseph Robinson & Sons [7], Walker v. Carnaby, Narrower, Barham & Pykett? ... John Reynolds & Co. (Insurances) Ltd. [9].1 stress that it is the character of the receipt in the recipient's hands that is significant; the motive of the payer is only significant so far as it bears, if at all, on that character. ... Gian Singh & Co. Ltd., [1976] S.T.C. 282 (P.C.), Lord Fraser stated, at pages 284-85: Questions of whether sums awarded by courts are income, liable to income tax, or not, have arisen in a number of reported cases. ...

On March 14, 1973, this Syndicate, in an arm’s length transaction, sold the Bel Air Apartments in Edmonton to knowledgeable real estate operators,* [1] for $5,850,000 which was allocated pursuant to the agreement between the parties as follows: to land — $5,100,000 and to “equipment, buildings, roads, sidewalks etc” — $750,000. It should be noted that on March 7, 1973, Skalbania made an unsolicited offer for the same Bel Air Apartments without prior negotiation or consultation, of $5,600,000 subject to the following valuation breakdown: land — $2,600,000; buildings — $2,400,000; and “trucks, equipment, roads etc” — $600,000. ...

“a plan is being developed by which the shareholders — other than Westinghouse Electric Corporation — will be offered benefits in lieu of those which otherwise would have been available in the original proposed sale to White Consolidated Industries”. ... This distinction is reflected in Seymour v Reed, [1927] AC 554, and Moore v Griffiths, [1972] 3 All ER 399, cases involving special payments to athletes in recognition or appreciation of their achievements, and in Walker v Carnaby, Narrower, Barham & Pykett, [1970] 1 All ER 502, and Simpson v John Reynolds & Co (Insurances) Ltd, [1975] 2 All ER 88, cases involving voluntary payments to auditors and insurance brokers upon termination of their services, made in appreciation of those services and as a consolation for their termination. ... Like it, they were made without legal obligation, but to make it easier for the recipient to accept what could be considered to be an adverse turn of affairs — in other words, for reasons of goodwill. ...

Notwithstanding this concession, the Board found that there were two issues before it which were defined as follows: On the question of jurisdiction it is the Board’s view that the first issue to be resolved is not one of liability for the tax but the general issue — whether or not the mixing and grinding of beef trimmings and boneless beef constitute the manufacture or production of goods (hamburger) within the meaning of Schedule III, Part XIII, section 1 (i) of the Act. ... Do you accept that — both parties accept that? Mr Gordon, is your position that the ground meat operation is manufacture or production? ... It seems to me that the only issue — certainly the declaration can be framed that they are entitled to the exemption or they are not entitled to the exemption but it seems to me that the issue before the Board is whether Loblaws is a manufacturer or producer, so that — and it seems to me that on this view of the issue there is no issue as to whether the goods are — whether there is manufacturing or producing. ...

The case came on for hearing on the morning of May 3, 1984, and at the end of the argument, just before the noon recess, the presiding judge made known his reaction to the evidence heard and explained his views as to law concluding the whole by stating: ”... ... The Court shall give reasons for its decisions but, except where the Court deems it advisable in any particular case to give reasons in writing, the reasons given by it need not be in writing. 171.(1) Disposal of appeal. — The Tax Court of Canada may dispose of an appeal by (a) dismissing it; or (b) allowing it and (i) vacating the assessment, (ii) varying the assessment, or (iii) referring the assessment back to the Minister for reconsideration and reassessment. 171.(4) Copy of decision to Minister and appellant. — Upon the disposition of an appeal, the Tax Court of Canada shall forthwith forward, by registered mail, a copy of the decision and any written reasons given therefor to the Minister and the appellant. ... It is true also that there are judgments which urge that only in exceptional circumstances could a judge consider altering a decree after verbal utterance (without however — it ought to be noted — giving any indication as to what could qualify as exceptional circumstances and whether the limitation would be based on a legal principle or on a moral or practical requirement). [3] But I know of no case where the jurisdiction of a judge to vary a verbal pronouncement made in open court prior to the entering of a formal judgment has been denied. ...