Search - 赤峰 二中 初中学区划分 2025

24 March 2025- 11:12pm Excavations Marchand – Court of Quebec finds that a construction company’s equipment used to provide concrete at a construction site qualified as for manufacturing goods for sale Email this Content A construction company contracted with Hydro-Quebec for the installation and operation of an on-site portable concrete-producing facility for the provision of the concrete in the installation of a large hydro-electric dam at a remote location. ... Agence du revenu du Québec, 2025 QCCQ 378 under Class 29 and Reg. 1104(9)(c). ...

5 February 2025- 8:02am Bell Canada – Federal Court of Appeal finds that Ontario electricity suppliers made single supplies of electricity notwithstanding separate regulatory and delivery charges Email this Content Bell Canada was required as a result of ETA s. 236.01 and the related regulation to recapture 100% of the input tax credits that it claimed in respect of the 8% Ontario HST that it paid on the consideration for the supplies to it in Ontario of electricity. ... In affirming this finding, Boivin JA distinguished Kevin Davis Dentistry, which gave effect to the expressed Parliamentary intent to “provide for different tax treatment of supplies of orthodontic appliances and orthodontic service” whereas, here, the Ontario regulations did “not amount to as clear an indicator of Parliament’s intent as the GST Act did in Kevin Davis Dentistry ”. ... Canada, 2025 FCA 27 under ETA s. 123(1) – supply. ...

9 February 2025- 11:19pm Pyxis Real Estate – Ontario Court of Appeal finds that capital dividends were agreed to be paid in amounts that overlooked a CDA deficit: no rectification Email this Content A plan was implemented for successive capital dividends to be paid up a chain of corporations so that the individual who was the ultimate shareholder could have a tax-free receipt of $1.4 million. ... The agreement here was for a $1.4 million tax-free capital dividend to be paid. … The fact that the agreement did not result in the intended fiscal objective of being tax-free, or tax neutral, is not a basis for granting rectification. ... Canada (Attorney General), 2025 ONCA 65 under General Concepts – Rectification. ...

28 March 2025- 12:33am Seabridge – BC Supreme Court finds that pre-feasibility expenses to assess whether a deposit could potentially support a mine qualified as exploration expenses Email this Content Seabridge incurred various pre-feasibility expenses in relation to a large and complex gold-bearing deposit in BC. ... Summary of Seabridge Gold Inc. v British Columbia, 2025 BCSC 558 under s. 66.1(6) – CEE – (f). ...

15 April 2025- 11:35pm 1084204 B.C. – BC Court of Appeal finds that an acquisition of a BC residential property by a foreign entity merely as agent for a resident was subject to 20% LTT Email this Content The respondent (“108”) was a BC company whose shareholder was a foreign national (Mr. ... Ltd., 2025 BCCA 110 under PTTA, s. 1 – taxable transaction – (a)(i). ...

20 January 2025- 11:16pm Bank of America – Federal Court of Appeal finds it reasonable of CRA to not extend an application deadline where the taxpayer failed to show due diligence Email this Content The Bank applied pursuant to ETA s. 141.02(19)(b)(ii) to CRA for an extension to the time for being able to apply to use a method for calculating its input tax credits (ITCs) that produced a better result than what it otherwise would have been entitled to. In dismissing the Bank’s appeal from a finding of the Federal Court that CRA’s rejection of this request was fair and reasonable, Mactavish JA found, regarding CRA’s finding that the Bank had failed to exercise the requisite degree of care respecting its filing obligations that would be expected of a sophisticated taxpayer, that “the Bank has not shown any reversible error with respect to this factually suffused finding” and also noted that “this Court has already determined that it is reasonable for the Minister to have regard to the diligence of a taxpayer in circumstances such as this: Denso Manufacturing … 2021 FCA 236”. ... Canada (Attorney General), 2025 FCA 9 under ETA s. 141.02(19)(b)(ii). ...

29 January 2025- 11:19pm Shull – Federal Court finds a breach of procedural fairness by the Tax Court did not require it to allow the taxpayer’s appeal Email this Content The taxpayer, who had limited ability to represent himself due to cognitive impairment, was using an agent in his Tax Court hearing until the agent (who had been identified in other proceedings as a vexatious litigant) resigned due to the expressed concerns of the Tax Court regarding such representation. ... Shull’s procedural fairness rights by refusing the adjournment” – but in nonetheless dismissing the taxpayer’s appeal applied the principle (in light of the weakness of the taxpayer’s case) that “where the result is inevitable, a court may exercise its discretion to not grant a remedy for the breach” of procedural fairness. ... Canada, 2025 FCA 25 under s. 180(3). ...

17 February 2025- 11:49pm Structures GB – Quebec Court of Appeal finds that corporate reorganization documents could not be rectified to correct for an unforeseen Pt. ... Structures GB Ltée, 2025 QCCA 134 under General Concepts – Rectification. ...

18 February 2025- 11:21pm Matte – Tax Court of Canada finds that the settlement of forgivable advances to an employee for less than the outstanding amounts produced s. 6(15) income Email this Content The taxpayer, who was employed at a wealth management firm, had received over $1 million in interest-free loans (evidenced by promissory notes) from predecessors of his employer which, by their terms, were forgivable in the employer’s discretion as to 10% each year, and were required to be repaid as to the balance on termination of his employment. ... The King, 2025 TCC 16 under s. 6(15), s. 12(11) – investment contract and s. 248(26). ...

23 February 2025- 10:41pm DAC – Federal Court of Appeal refuses to allow a third party to intervene in the DAC (avoidance of CCPC status) case Email this Content The moving party (“QPG”) sought an order pursuant to Rule 109 of the Federal Courts Rules to permit it to intervene in the Crown’s appeal of the DAC decision, which found that there was no GAAR abuse in DAC continuing to the British Virgin Islands so as to cease to be a Canadian-controlled private corporation (CCPC). ... Before dismissing the motion to intervene, Stratas JA stated that “[t]he issue raised by QPQ … seeks to reinvent the theory of the case” and that “[t]his is a classic case of a proposed intervention that, if allowed, will commandeer the parties’ case.” ... DAC Investment Holdings Inc., 2025 FCA 37 under Federal Courts Rules, Rule 109. ...