Search - 赤峰 二中 初中学区划分 2025

25 February 2025- 11:26pm Evans – Ontario Superior Court grants an order rectifying a trust allocation resolution so as to set out specific amounts Email this Content After a discretionary family trust realized a capital gain from a share sale, the sole trustee passed a resolution in that year providing that “[t]he income of the Trust be allocated to the [three stated] Beneficiaries of the Trust payable by way of demand Promissory Note in such amounts to be determined when the income of the Trust is ascertained ….” ... Attorney General of Canada, 2024 ONSC 1955 under General Concepts – Rectification. ...

14 January 2025- 10:30pm 267 O'Connor – Tax Court of Canada finds that damages paid by the vendor under a failed realty sale did not generate ITCs notwithstanding some IP transferred to it Email this Content In the settlement of an action against it by a third party (“Starwood”) for a failure of a property sale agreement to Starwood to close, the appellant agreed to pay $450,000 to Starwood and Starwood agreed to provide a release and to hand over all its rezoning application plans and reports (reflecting that between the signing of the purchase agreement and the scheduled closing date, it had taken over the carriage of an OMB appeal regarding the property). ...

2 February 2025- 11:42pm Raiche – Court of Quebec finds that a suspended Quebec police officer had not severed his Quebec ties when he started living (except when in Quebec) with his son in Ontario Email this Content Raiche started living with one of his two sons in Petawawa Ontario when, in November 2015, he was suspended from his employment with the Quebec police force in connection with a criminal investigation of him. ...

7 January 2025- 11:14pm CIBC – Tax Court of Canada finds that CIBC’s interchange fees from a non-resident credit-card processor were not zero-rated as relating to the loans effectively made to its Cdn. cardholders Email this Content CIBC had outsourced part of its Visa-card operation to an arm’s length non-resident (“GPDI”) so that, in a typical transaction in which a Canadian cardholder presented their CIBC Visa card to a Canadian merchant, GPDI would process the point-of-sale information received from the merchant and transmit it to CIBC for credit authorization, transmit the authorization (assuming no “decline”) back to the merchant and send this and the other day’s transactions to VISA for clearing, following which there was a process involving CIBC, GPDI and VISA by which the settlement funds were paid to the merchant. ... Before concluding that the interchange fees were not zero-rated on the basis of the exclusion in ETA VI‑IX‑1(a)(ii) for a service that “relates to (a) a debt that arises from … (ii) the lending of money that is primarily for use in Canada”, Sommerfeldt J found that: regarding the “relates to” test, “there only needs to be ‘some connection’ between the interchange services and the debt described in the carve‑out; in this context the verb “lend” should have “a broad meaning (recognizing that a loan arises when the lender, at the request of the borrower, pays money to a third party in satisfaction of an obligation owed by the borrower to the third party)”, so that “when a Cardholder used a CIBC Visa Card in respect of a transaction, CIBC loaned to the Cardholder, and the Cardholder borrowed from CIBC, the monetary amount of the transaction” (even though the funds went to the merchant); “in a tax context, the word primarily generally means (among other things) principally, mainly, most importantly, or more than 50% ”; and “the loaned money was used to pay merchants located in Canada” so that “the money paid by CIBC indirectly to the merchants (i.e., through the Visa Payment System), in satisfaction of the Cardholders’ obligations to the merchants, was loaned money that was primarily for use in Canada”. ...