Search - 辐射监测仪 校准

17 February 2019- 11:35pm Ark Angel Foundation – Federal Court of Appeal confirms CRA’s revocation of charitable registration for paying unsubstantiated consulting fees to a director Email this Content The Foundation, a charitable foundation, received most of its revenues from three other registered charities (including the Humane Society of Canada Foundation) that were dominated by the same individual, and disbursed most of those revenues to those three charities, except that it paid approximately 1/3 of its revenues to the individual. ...

Fogler Rubinoff – Ontario Superior Court of Justice stays a negligence action against a law firm pending disposition of the related tax appeal Email this Content An estate sued its law firm in negligence after CRA assessed it over $9 million on the basis that the method used to transfer shares to a charitable foundation did not generate a donation credit. ...

21 March 2019- 11:56pm Prince – Federal Court finds that a 30-day letter is not a judicially-reviewable “decision” Email this Content Annis J found that a CRA “fairness” letter to the taxpayer setting out proposed reassessments for his 2007 to 2016 taxation years and giving him 30 days to provide additional information and representations was not a “decision” that he had the jurisdiction to review under the Federal Courts Act. ...

10 April 2019- 12:06am Sunshine Coach – Tax Court of Canada finds that Alberta bus tours were separate from international flights for ETA zero-rating purposes Email this Content ETA Sched. ...

23 April 2019- 12:59am Kyard Capital – Court of Quebec finds that it was unnecessary to waive privilege in order to substantiate the nature of legal services provided Email this Content The individual taxpayer (“Fontaine”), who was the president and majority shareholder of a corporation (“Kyard”), was assessed under the Quebec equivalent of s. 15(1) when Kyard paid his fees for defending against an action brought against him by his ex-spouse. ...

6 June 2019- 11:09pm Rasmussen – Tax Court of Canada finds that Australian pension plan payments were fully taxable in Canada even though previous contributions had been non-deductible Email this Content An Australian police officer made non-deductible contributions to a “QSuper" government pension plan and then, when he became disabled, started receiving periodic “pension” amounts, a portion of which was non-taxable for Australian tax purposes. ...

4 July 2019- 11:05pm Many Mansions – Federal Court of Appeal confirms revocation of charity’s registration on the grounds that it let its pastor occasionally use office space in his personal business Email this Content Laskin JA confirmed CRA’s decision to revoke the charitable registration of a charity (Many Mansions, whose object was advancing Christian tenets and observances) on various grounds, including that it “furnished its pastor with an office and permitted him on three occasions during the audit period to use meeting rooms on Many Mansions’ premises in operating a private business.” ...

18 July 2019- 12:08am Singh – Tax Court of Canada accepts a written director’s resignation that was not fully recorded Email this Content Similarly to ITA s. 227.1(4), ETA s. 323(5) indicates that a director’s assessment under ETA s. 323 is invalid if made more than two years after the individual ceased to be a director. ...

8 August 2019- 12:24am Gekas – Federal Court finds that CRA’s denial of relief from penalty tax on TFSA over-contributions relating to errors of the financial institution was unreasonable Email this Content S. 207.06(1) indicates that the Minister may waive the tax on an excess TFSA contribution where “the individual establishes to the satisfaction of the Minister that the liability arose as a consequence of a reasonable error” and the excess (together with any income thereon) is distributed “without delay.” ...

11 August 2019- 11:41pm Connolly – Tax Court indicates that there may be no authority for a Notice of Confirmation to pass on subsequent taxation years Email this Content Before going on to grant the taxpayer’s claim for a disability tax credit for her 2014 taxation year (but not the three earlier years), Jorré DJ noted that the Minister in her Notice of Confirmation had indicated that the taxpayer was eligible for the DTC for her 2015 and later years even though the Notice of Confirmation was dated before her filing-due date for her 2015 year, and stated obiter: [I]t would be surprising if on a proper interpretation the relevant statutory provisions gave the Minister the power to make a determination with respect to future eligibility. ...