Search - 赤峰 二中 初中学区划分 2025

26 January 2025- 10:47pm Vorsteveldt – taxpayers are challenging the CRA administration of the 2/3 CGIR Email this Content Ms. ... (Canada), 24 January 2025 Application pursuant to ss. 18 and 18.1 of the Federal Courts Act under s. 38(a) (see also Pelco Holdings v. ... (Canada), 24 January 2025 Application pursuant to ss. 18 and 18.1 of the Federal Courts Act). ...

4 May 2025- 11:17pm Delta 9 Cannabis – Alberta Court of King’s Bench determines that a reverse vesting order should not permit the target corporation to transfer out future s. 80 income tax liabilities Email this Content A cannabis producer (“Bio-Tech”) had entered CCAA proceedings. ... Summary of Delta 9 Cannabis Inc (Re), 2025 ABKB 52 under s. 80(13) and summary of Chris Lang, “Debt Restructuring Using a Reverse Vesting Order: Tax Issues,” Canadian Tax Focus, Vol.15, No. 2, May 2025, p. 2 under s. 80(13). ...

4 March 2025- 10:37pm RTI – Court of Quebec confirms that it had no jurisdiction to deal with over-remittances of source deductions Email this Content Couture JCQ confirmed that the Court of Quebec had no jurisdiction to consider a Notice Of Objection of the taxpayer based on the failure of the ARQ to refund source deductions which it alleged that it had over-remitted, given that the Quebec equivalent of ITA s. 171(1) only accorded the Court of Quebec jurisdiction to deal with assessments. ... Agence du revenu du Québec, 2025 QCCQ 231 under s. 171(1). ...

28 April 2025- 1:41am CRA indicates that the granting of power of attorney over shares would not change the shares’ ownership for purposes of the s. 120.4 – excluded share definition Email this Content An adult child, who was over 24 and a “specified individual,” received a distribution of 10% of the common shares of a CCPC from a family trust, of which his father (a “source individual”) was one of the two trustees, then he granted his father a power of attorney (POA) regarding those common shares, pursuant to which his father could exercise all rights attached to those shares except as expressly excepted. ... Summary of 12 March 2025 External T.I. 2025-1053231E5 under s. 120.4(1) – excluded share – (b). ...

9 March 2025- 11:17pm 1351231 Ontario – Federal Court of Appeal confirms that conversion of the use of a condo from long-term rental to an Airbnb property caused its subsequent sale to be taxable Email this Content The Appellant used a condo unit for the first nine years after purchase for long-term residential rentals and then listed it on Airbnb and rented it out for succession of short-term rentals (under 60 days and sometimes for only one night) before its sale. ... Canada, 2025 FCA 53 under ETA s. 123(1) – residential complex. ...

25 March 2025- 11:17pm IWK Health – Tax Court of Canada finds that employers could not claim HST on the reimbursed health care expenses of their employees Email this Content Some Nova Scotia hospitals reimbursed (through a health care plan administrator) their employees for the employees’ costs including HST of acupuncture, massage therapy, naturopathy, or homeopathy services. ... Accordingly, these services did not satisfy the s. 175 test of being “for consumption or use … in relation to activities” of the hospitals. ... The King, 2025 TCC 44 under ETA s. 175(1). ...

16 January 2025- 12:17am Doostyar – Federal Court of Appeal indicates that judgments should not be provided to the parties in draft for non-substantive comments Email this Content The Tax Court judge sent a draft judgment (disallowing the taxpayers’ appeal) to the parties and asked for their comments on any “typographical, grammatical, punctuation, or [any] similar error[s] or any omissions” and any “comments in respect of the written presentation of…[the] decision”, but not so as to revisit the substance of the decision. ... Canada, 2025 FCA 6 under s. 171(1). ...