Search - 深圳居住证 办理条件 最新政策

The appellant attempted to deduct, from its 1974 taxation year, income in the amount of $13,098 on certain insurance policies set out as follows: Sun Life $ 395 Maritime Life Re Policy 154510 $ 2,998 Maritime Life Re Policy 206223 $ 1,004 Maritime Life Re Policy 154503 $ 8,701 $13,098 In this regard, at the outset of the hearing, it was agreed by both counsel for the appellant and counsel for the respondent that deduction of the Sun Life policy premium in the sum of $395 not be allowed; that the deduction of the premium for the Maritime Life Policy number 154510 be allowed; that the deduction of the premiums for the Maritime Life policy number 206223 be allowed; leaving in dispute and in issue the deductibility of premiums paid on Maritime Life Policy number 154503. ... A letter was filed from Aetna dated February 21, 1973, addressed to the accountants for Direct Lumber which reads as follows: (Exhibit A-15) AETNA FACTORS February 21, 1973 Goldfarb, Shulman & Co., 3077 Bathurst Street, TORONTO 19, Ontario. ... JAR Leaseholds: (1) Registered General Assignment of Book Debts — Accounts receivable — Oct 31/72 — $892,629.46 (2) Personal guarantees given by: John Fabry Mrs. ...

The land that had been purchased had been bought with the set intention of building a large housing complex; this would not have been detrimental to Steinberg’s operations — rather the contrary. ... Promise of sale signed August 21, 1964 Calculation of reserve according to section 85-B May 31/65— 85,649.20 x 247,000.00 = 82,316.54 257,000.00 ===== May 31/66 85,649.20 x 181,565.80 = 60,505.70 257,000.00 ===== May 31/67 85,649.20 x 150,000.00 49,989.80 257,000.00 == Confederation Life mortgage assumed Un- Initial Cost Accumulated depreciated Edifice Ferland Land Building Depreciation Balance April 3/64—Purchase $8,500.00 $239,000.00 $239,000.00 Additions 877.90 877.90 239,877.90 239,877.90 May 31/64—C.C.A. 11,950.00 11,950.00 Balance $8,500.00 $239,877.90 $11,950.00 $227,927.90 May 31/65—C.C.A. 11,396.40 11,396.40 Balance 8,500.00 239,877.90 23,346.40 216,531.50 Additions 25,439.10 25,439.10 $8,500.00 $265,317.00 $23,346.40 $241,970.60 Oct. 5/65—Sale Selling price 450,000.00 Less: Commission 15,000.00 $435,000.00 8,500.00 426,500.00 Total profit $184,529.40 Recovered in C.C.A. 23,346.40 Surplus over initial cost 161,183.00 $184,529.40 Terms of sale Selling price $450,000.00 Cash 100,000.00 Balance $350,000.00 by the purchaser 350,000.00 Place des Chênes Shopping Centre Un Un- Initial Cost Accumulated depreciated Land Building Depreciation Balance Aug. 9/63 Purchase $45,543.00 Construction 3,037.40 $305,007.65 305,007.65 48,580.40 305,007.65 305,007.65 May 31/64 C.C.A. $15,250.38 15,250.38 Balance 48,580.40 305,007.65 15,250.38 289,757.27 Additions 30,881.31 30,881.31 $335,888.96 $15,250.38 $320,638.58 May 31/65 C.C.A. 16,031.93 16,031.93 Balance 48,580.40 335,888.96 31,282.31 304,606.65 Mar. 18/66 Sale Selling price $375,000.00 48,580.40 326,419.60 Recovered in C.C.A. $21,812.95 If we analyse the statements made by the witnesses before the Board, we can see that no reliance can be put on appearances. ...

Minister of National Revenue, [1982] CTC 2302, 82 DTC 1332 D E Taylor:—These appeals, heard on common evidence in Edmonton, Alberta, on February 10, 1982, were lodged against income tax assessments for the following years: Dr Lloyd G Powell (“Powell”) — 1975 & 1976 Polaris Holdings Ltd (“Polaris”)— 1975 & 1976 Mr Neil G Orser (“Orser”) — 1975 Mr Michael Piro (“Piro”) — 1975 There were four matters at issue in these appeals, all gains on sales or property — the total appeal therefore in all aspects reflects a “trading case” dispute. ... Triple Crown — Powell had lived on an “acreage” lot in the country ever since moving to Edmonton; — He liked horses; — He considered the prospect of raising horses in his retirement years would be a good objective; — Triple Crown would have been suitable, as a matter of fact, because it had 160 acres as opposed to 40 at the present farm site which, for location reasons only, was more suitable; — On the sale of Triple Crown, he immediately purchased a new “horse” farm — the current 40 acres, and has invested some $250,000 therein. Apartment — This purchase was in the same manner as the other rental holdings in Yellowknife. — The decision to sell had been that of Ibrahim, not Powell. ...

In his returns for the said years, he stated as present employer — “Pioneer Life”. ... In filing his 1975 T-1 tax return, the appellant claimed and the respondent subsequently allowed the following expenses: 1975 Expense claimed (as filed Item per return) Allowed Disallowed Car Expenses: Interest $ Nil $ 417.48 Insurance Nil 137.67 Gasoline 1,109.33 367.87 Maintenance & repairs 999.92 770.35 CCA 1,590.00 1,184.02 $3,699.25 $2,877.39 Less 35% personal use Nil 1,007.09 $3,699.25 $1,870.30 $1,828.95 Licence 133.00 133.00 Nil Parking 45.00 45.00 Nil Car Washes 33.50 33.50 Nil Advertising & Promotion 82.00 90.25- 8.25 Travel & Accommodation 208.78 Nil 208.78 Entertainment 506.19 269.32 236.87 Training allowance 190.00 190.00 Nil Telephone 75.35 29.55 45.80 Office Equipment & Supplies 854.50 10.37 844.13 Winnipeg Flying Club 646.58 318.01 328.57 $6,474.15 $2,989.30 $3,484.85 5. ... With respect to “Fire & Liability Insurance”, I find that this is not a legitimate expense under the circumstances. ...

Minister of National Revenue, [1981] CTC 2400, 81 DTC 281 D E Taylor:—This is an appeal heard in Toronto, Ontario, on February 23, 1981, against an income tax assessment for the year 1976 in which the Minister of National Revenue disallowed an amount of $1,054.61 claimed by the taxpayer as “moving expenses’’, described by an appellant as: — non-capital carrying costs on unoccupied residence for sale $ 775.00 —extra cost due to equity being tied up in house as a result of moving 279.61 $1,054.61 For the purposes of the hearing the appellant revised his claim and provided additional detail: — existing carrying costs on house for sale (mortgage interest and property taxes) $ 832.12 — interest on loan necessitated by move from Kitchener to Hamilton (Note: This is not the regular mortgaging on either residence, $24,300.00 @ 12 /4% for 35 days) 279.61 Counsel informed the Board that the Minister was prepared, for purposes of the hearing, to accept the mathematical validity of the $832.12 rather than the $775 since the appellant stated the earlier amount had only been an estimate. ... The expenses claimed are: — not specifically excluded — not to make the former residents more saleable —not in respect of any loss on sale of former residence —not in respect of any capital expenditure on new residence, (in other words, they are costs related purely to moving) —reasonable, and all the requirements of section 62 are met. 2. ... (ii) With regard to IT-178R2 The expenses claimed are: — reasonable — not specifically excluded — not to make property more saleable — not in respect of any loss on sale —not in respect of any capital expenditure and otherwise all the requirements of section 62 are met (iii) If the cost of cancelling and unexpired lease on former residence is deductible (and it is)—excluding any rental payment for a period during which the residence was occupied (exactly my situation—I am claiming under (b), in lieu of rent, interest and property taxes while the house was unoccupied), why is my bridge financing, also due timing of move, not deductible? ...

His reported financial results from the activity were as follows: 1975 1976 Gross Revenues $13,791.50 $14,789.76 Expenses $ 8,996.70 $ 7,486.61 Net Profit $ 4,794.79 $ 7,303.15 It was common ground that the appellant was self-employed, was taxable on the profits from his business and was not subject to the restrictive provisions of the Income Tax Act which govern the computation of income from employment. ...

The taxpayer reported, on his return of income for the 1975 taxation year, a capital gain on the disposition of the following property (all in the Province of Manitoba (“the property”)): S / 18-35-25W S / 28-35-25W S / 20-35-25W S / 17-35-25W SE /4 7-35-25W NE /4 8-35-25W The reported proceeds of disposition on the property were $170,000. ... A real estate listing agreement dated February 12, 1975 between the appellant and C & L Realty Limited was also introduced into evidence as Exhibit A-20. ... Write stating full particulars to: C & L Realty, 2727 Portage Avenue, Winnipeg, Man. ...

As Exhibit A-1, he filed a two-page document headed “Expenses 1978”; these expenses are as follows: Advertising and promotion: $ 50.00 Insurance (on musical instrument): 38.00 Interest (loan for van and musical equipment): 1,274.00 Maintenance and repairs: 85.00 Supplies and materials: 489.00 Office expenses: 13.00 Telephone: 25.00 Musical instruction: 192.00 Truck expenses (including: insurance —$237; engine repairs — repairs — $400; automatic transmission repair — $498, etc) 1,705.00 $3,871.00 Capital cost — $2,709.68 Additions — bass guitar, electric organ, speakers, microphones 744.47 $4,615.47 In the income tax return the Capital Cost Allowance 20, vouchers were also filed concerning the van expenses. ... Law — Analysis 4.01 Law The main sections of the Income Tax Act involved in the present case were paragraphs 18(1)(a), (h) and section 248, definition of “personal or living expenses”, which read as follows: 18. (1) General limitations. ... As he declared $675 of income (despite the fact that the actual amount received is not clear — see subparagraph (a) above). ...

In fact, the appellant had his office in the same building as A H Roy & Associates. ... The assets of A H Roy & Associates could not be taken into consideration in evaluating the goodwill. ... McNeely, Lecompte & Associates Limited was then incorporated, with the appellants as principal shareholders. ...

In 1969 Warwick Bros & Rutter Co Ltd, Karr's Inc, Mutual Wholesale Stationery Limited, Viscount Plastics (Canada) Limited and Bedisco Inc were also purchased, and I believe the appellant company caused another company, Bel-Air Stationers Ltd, to be incorporated. 5 In general, through its wholly-owned subsidiaries, the appellant company dealt in stationery for schools and offices, and in general business supplies, and each of the companies acquired either specialized in a certain type of stationery, or had a name favourably well known in that field of business not only locally but in other parts of the country. 6 In 1969 the appellant became a listed public company. ... This statement was part of the auditors' report to the directors of the appellant company by Peat, Marwick, Mitchell & Co, Chartered Accountants, dated May 21, 1970, and was presented in slightly different form from the annual report to the shareholders filed as part of Exhibit A-3. 11 Fanco Products Inc was a manufacturer of brief-cases, attaché cases, binders and schoolbags. ... Stewart & Morrison Limited, a decision of the then Exchequer Court of Canada ([1970] C.T.C. 431, 70 D.T.C. 6295) upheld by the Supreme Court of Canada ([1972] C.T.C. 73, 72 D.T.C. 6049), as reported at page 438 [6299]: The question for determination is what was the true nature of the advances that made up the amount claimed as a deduction by the respondent. ...