Search - 赤峰 二中 初中学区划分 2002

Robert Kreklewetz, Brent Murray, "Ontario Software Changes 2002- Another Nail in the Coffin", GST & Commodity Tax, Vol. XVI, No. 7, September/October 2002, p. 49.-- summary under Regulation 1012-14.2(2) Summary Under Tax Topics- Other Legislation/Constitution- Ontario- Retail Sales Tax Act- Regulation 1012-14.2(2) ...

., Sweet & Maxwell, 2002-- summary under Subsection 248(20) Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(20) Partition at common law (p. 327) Joint tenants and tenants in common have always been able to make a voluntary partition of the land concerned if all agreed; their co-ownership thus comes to an end as a result of each of them becoming sole tenant of the piece of land allotted to him. ...

– Part II", Tax Topics, Wolters Kluwer, No. 2274, October 8, 2015, p.1.-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission Test is one simply of true intention, not specific intent (pp. 3-4) In Juliar,…[t]he key passages from the Court of Appeal are these:… [I]t is possible,, even probable, that no one mentioned income tax throughout the nine or 10 months in issue. ... Sylvan Golf & Tennis Club Ltd. [fn 9: 2002 SCC 19 at paragraph 66.] the Court said: "I conclude that due diligence on the part of the plaintiff is not a condition precedent to rectification. ... If there is no requirement for due diligence, it means that rectification is available even when there is a mistake — even a negligent mistake [f.n. 10. ...

Carrie Aiken, Johnson Tai, "Debt Restructuring Transactions – Issues, Strategies and Trends", 2016 CTF Annual Conference draft paper-- summary under Subsection 39(2.02) Summary Under Tax Topics- Income Tax Act- Section 39- Subsection 39(2.02) Background to s. 39(2.01) (pp. 13-14 Many Canadian companies have or had significant accrued foreign currency gains in their US dollar denominated debts, particularly where the debts were originally issued in 2001 or 2002…. ...

[fn 39: S & D International Group Inc. v. Canada (Attorney General), 2011 ABQB 230, at paragraph 106.] ... In order to get rectification it is necessary to show that the parties were in complete agreement on the terms of their contract, but by an error wrote them down wrongly; and in this regard, in order to ascertain the terms of their contract, you do not look into the inner minds of the parties – into their intentions – any more than you do in the formation of any other contract. ... Sylvan Lake Golf & Tennis Club Ltd., 2002 SCC 19, at paragraph 31] (the other non-tax-related decision): (1) the existence and content of the inconsistent prior oral agreement; (2) that the party seeking to uphold the terms of the written agreement knew or ought to have known about the lack of correspondence between the written document and the oral agreement, in circumstances amounting to fraud or the equivalent of fraud; and (3) "the precise form" in which the written instrument can be made to express the prior intention. ...

In 1954 the words ‘‘on behalf of '' were added. This phrase was changed to ‘‘in the name of '' — the literal wording of the French version — in 1958 for no discernible reason.... ... Federal Commissioner of Taxation, [2002] NSW SC 1115 (December4, 2002). ... Dell – commissionaire did not act for principal (p. 14) In Dell Products (NUF) v. ...

The Queen …, [fn 5: Sub nom water's Edge Village Estates (Phase II) Ltd., … 2002 FCA 291 ….] the Tax Court in Triad Gestco Ltd. v. The Queen…, [fn 6: … 2011 TCC 259 …aff'd … 2012 FCA 258 …] and, in the context of a provincial general anti-avoidance rule, the Court of Québec in Ogt Holdings Ltd. c. ... The Queen … [fn 25: … 2008 TCC 274, para. 121; aff'd … 2009 FCA 113.] and 1207192 Ontario Ltd. v. ...

[fn 26: … 2009 TCC 118. para. 47.] More recently, however, in On-Line Finance & Leasing Corp. v. ... Tax Court (p. 477) …the "stranger to the contract rule" is treated as an additional exception to the parol evidence rule, [fn 30: US: CA. 2002, Deckard v. General Motors Corp., 307 F.3d.556 (2002), p. 565] has been described by the US Tax Court as follows: [fn 31: US: TC, 1969, Brown v. ...

Groupe Honco finding of multiple "main" purposes (pp. 9-10) In Groupe Honco (… 2013 FCA 128)…[t]he FCA said, "The phrase 'one of the main purposes' is unambiguous and implies that a taxpayer may have more than one main motive in acquiring shares. ... " … (The UK decisions referred to are Prudential Plc v. Revenue & Customs, [2007] UKSPC 636; IRC v. Trustees of the SEMA Group Pensions Scheme, [2002] STC 276 (Ch. D); IRC v. ...

Kandev, "Foreign Affiliate Issues in Troubled Times", International Tax (Wolters Kluwer CCH), No. 112, June 2020, p. 1-- summary under Paragraph 95(2)(g.1) Summary Under Tax Topics- Income Tax Act- Section 95- Subsection 95(2)- Paragraph 95(2)(g.1) S. 95(2)(g.1) applies on the basis of whether interest would be deductible from FAPI (pp. 2-3) 2002-0165195 … (the "2002 Technical") … [considering] that the forgiveness of a debt made by Canco to CFA1, the proceeds of which were used by CFA1 to acquire shares of CFA2 would not give rise to the application of the debt forgiveness rules because the debt was used to earn dividends from an FA and that such dividends are not to be included in the FAPI …. was overridden … in … 2004-0062175 … (the "2004 Technical") …. ... Potential application of s. 248(27) where dual-use debt (p. 3) [R]espect[ing] debt partly used for the purposes of earning FAPI and partly used for the purposes of earning active business income … the 2002 Technical … took the position that the whole amount of such debt would constitute a "commercial debt obligation" …. ...