Search - 辐射监测仪 校准

10 July 2017- 12:19am Grant – Tax Court of Canada finds that the six-month CRA filing “requirement” in s. 227.1(2)(c) is merely directory Email this Content Smith J confirmed the finding in Kalef that the appointment of a trustee in bankruptcy did not cause an individual to cease to be a director notwithstanding that the directors were no longer in control. ...

2 August 2017- 1:18am McCullock-Finney Estate – Tax Court of Canada finds that merely filling in a T664 form was insufficient to step-up a property’s ACB under s. 110.6(19) Email this Content The taxpayer disposed of two rental properties in 2010 and calculated her capital gain on the basis that the properties’ adjusted cost base had been stepped up in 1994 through having made an election under s. 110(19) to utilize her otherwise-expiring capital gains deduction. ...

Brian Hurd Dentistry – Tax Court of Canada finds that an orthodontist did not make separate supplies of orthodontic appliances and services Email this Content Campbell J found that an incorporated orthodontic practice was making a single supply of exempt orthodontic health services rather than (as argued by it) two supplies comprised of a zero-rated supply of medical equipment (the orthodontic appliance) and of exempt orthodontic services (e.g., adjustment and maintenance services). ...

6 November 2017- 11:14pm RAR Consultants – Tax Court of Canada imposes penalties for failure to file T1134s respecting a foreign affiliate Email this Content In the years in question, the T1134 forms provided an exemption from the required filing where inter alia the cost amount of the taxpayer’s investment in foreign affiliates was less than $100,000. ...

29 November 2017- 1:37am Aubrey Dan Family Trust – Ontario Court of Appeal confirms that a federal form applied for Ontario purposes without any specific reference on its face to that effect Email this Content A purported Alberta trust, that wanted more time to make submissions to CRA that it was not resident in Ontario, provided a related waiver on the prescribed (T2029) federal form. ...

3 December 2017- 7:31pm University Hill – Federal Court of Appeal finds that a settlement agreement agreeing as to round percentages of expenses that were unreasonable accorded with Galway Email this Content Boivin JA found that a settlement agreement with CRA, that stipulated the disallowance of various categories of expenses incurred by film-production tax-shelter LPs or round percentages thereof or formula amounts, did not violate the Galway principle given that this was not inconsistent with s. 67, which could be applied to disallow only a portion of such expenses. ...

20 December 2017- 1:51am Groscki – Tax Court of Canada finds that a director was not liable for failure to obtain a s. 159(2) certificate before his corporation disposed of most of its assets Email this Content Bocock J appears to have found that a director was not a “legal representative” of a Macao-incorporated corporation that disposed of all of its inventory (being substantially all of its assets) without obtaining a s. 159(2) clearance certificate given inter alia that the director did not do a lot more than directors normally do and, in particular did not act as a liquidator given that there was no liquidation process authorized by the corporation nor any formal authority granted to him to act as a liquidator, de facto or otherwise. ...

7 January 2018- 5:57pm Zhang – Tax Court of Canada finds that “may deduct” means “is permitted to deduct” rather than “chooses to deduct” Email this Content The formula for an individual’s unused tuition, textbook and education tax credits states that it is reduced each year by “the amount that the individual may deduct” for that year. ...

31 January 2018- 7:01am Stadion Amsterdam – ECJ finds that a single supply of composite items is subject to a single rate of VAT Email this Content The operator of a soccer stadium had been found to be making a single supply of tours notwithstanding that participants were entitled at the conclusion of their tour to visit an on-site museum free of additional charge. ...

5 March 2018- 11:51pm VLN – Tax Court of Canada finds that work performed for 3rd parties did not qualify as the taxpayer’s own SR&ED Email this Content Lyons J found that work that the taxpayer performed for third parties using high tech equipment (the “System”) that it had purchased did not qualify as its SR&ED activities. ...