Search - 阿里拍卖 司法拍卖

. … [T]he CRA would be inclined, in situations similar to those described in the judgment, to accord tax treatment similar to that provided by the TCC in its judgment. ...

. … [T]he fact that a person advises a trustee should not in itself generally alter the location of central management and control of the trust at the trustee level. ...

. … [T]here is nothing in the Treaty that expressly provides where a gain described in paragraph 4 of Article 13 arises. ...

., " the selling price initially is fixed at a maximum equal to the fair market value at the time of the sale, but... this sale price can be reduced in accordance with a pre-established agreement if certain conditions are not met" so that on such reduction no reimbursement of the sale price occurs): the actual proceeds of disposition are not determinable at the time of disposition of the shares. ...

. … [W]here the payor failed to remit amounts withheld or deducted, the payor…is liable for the amount of the deductions that were not remitted together with the penalty for not remitting, and interest thereon. ...

. … Since the Taxpayer did not file the T2 returns within [the] three-year limit, the Minister does not have the authority to refund the overpayment to the Taxpayer. ...

. … [E]lement A.1 must be taken into account in calculating the CEC of CCPC for the 2008 to 2012 taxation years. ...

28 March 2013 External T.I. 2012-0465171E5 F- Frais médicaux- technicien en orthophonie-- summary under Paragraph 118.2(2)(l.9) Summary Under Tax Topics- Income Tax Act- Section 118.2- Subsection 118.2(2)- Paragraph 118.2(2)(l.9) services of speech therapy technician, who supplemented speech-language pathologist’s services, were ineligible as being unsupervised by a doctor After a physician’s referral, the taxpayer’s child (with a severe and prolonged impairment entitling the taxpayer to a credit for mental or physical impairment under s. 118.3) has been using the services of a speech-language pathologist in the private sector, who can only provide services to the child once every two weeks – so that for the other weeks, the child is seen by a specialized speech therapy technician to whom the child was referred by the speech-language pathologist. ...

. … [O]ne would be the brother of the other for purposes of the Act. ...

Therefore … if the Debt is subsequently repaid to Parentco, Debtor may be entitled to a refund of the Part XIII tax previously assessed. ...