Search - 阿里拍卖 司法拍卖

. … [T]he fact is that the same eighteen persons who formed the Partnership were the very same persons who comprised the Co-Tenancy. … [T]he agreement to pay the tenant inducement payment of $1.2 million was of no legal consequence and.. it cannot be considered an outlay or expense made for the purpose of gaining or producing income…. ...

The Queen, 74 DTC 6540, [1974] CTC 681 (FCA)-- summary under Interpretation/Definition Provisions Summary Under Tax Topics- Statutory Interpretation- Interpretation/Definition Provisions tags captured a broader range of operations than those specifically referenced In finding that the reference in the definition of “farming” to "maintaining" of horses for racing included an operation where the care and training of the horses was contracted out to independent contractors, Jackett CJ stated (at p. 6541): [T]he words “maintaining of horses for racing” were intended to apply not only to what is commonly thought of as the operation of a racing stable but also to the less pretentious business operations consisting of racing horses in circumstances where the businessman does not have his own stable and pasture premises and staff of “boys” and trainers …. This would seem to follow from the context of the definition where expressions such as ‘“tillage of the soil”, “raising of poultry” and ‘the keeping of bees” are obviously used, in each case, to refer to the whole gamut of operations constituting the particular class of business succinctly described by the words commonly used to describe it. … What was being done throughout the definition of “farming” was the adoption of short “tags” to indicate different types of operations. ...

In filing his returns for those years he deducted significant amounts for moving expenses, and received refunds for each year – but was later reassessed so that he was required to repay the refunds. ... Thurlow CJ stated at the conclusion of his reasons: As there was no statutory provision imposing an obligation to pay interest for the use of the refunds until the errors were corrected by reassessments, the taxpayer…was not liable for such interest …. ...

. … The idea that liability for capital tax would accrue in the relevant year regardless of when the tax was assessed… is consistent with the long established principle under the Income Tax Act that liability for tax arises not pursuant to the filing of a return or the issuing of an assessment or reassessment, but rather pursuant to the terms of the Income Tax Act itself [citing The Queen v. ... Riendeau ¸ 91 DTC 5416 (FCA); and subsection 152(3).] ...

MNR, 93 DTC 1473, [1993] 2 CTC 3148 (TCC)-- summary under Regulation 2902 Summary Under Tax Topics- Income Tax Regulations- Regulation 2902 The taxpayer unsuccessfully argued that interest expenses incurred by it to finance the payroll cost of its R & D personnel were not made for the purpose of generating expenses, not income, and therefore were not described in Regulation 2902(a)(c). ... " However, registration and travel costs arising from the attendance of R & D staff at computer software conferences were not denied by Regulation 2902(a)(F). ...

. … In other words, any action taken to obtain a tax benefit would be an avoidance transaction and there would never be an occasion to determine the primary purpose of a transaction. … The words of the Act require consideration of a transaction in its entirety and it is not open to the Crown artificially to split off various aspects of it in order to create an avoidance transaction. ...

. … If we refer to the definition of that term in this same reference work, we read: Consideration provided by the person who receives a benefit in the synallagmatic contract; reciprocal benefit (perceived as equal) charged to a party to a contract, for example, wages in consideration for work, or the price in consideration for the article sold. ... … We see from reading the agreements.. that the common intention of the parties is that, if the premises are destroyed, disposed of or expropriated, the full amount of the grant, that is, $880,660, shall be reimbursed, prorated according to the number of years remaining. ...

. … It is clear that both the Annuitants and the Promoters intended the purchase price for the shares be the stated purchase price. … They misled the Applicant with respect to the value of the shares purchased by the RRSPs but this is not a "sham. ...

. … As noted in Sattva [2014 SCC 53], considering surrounding circumstances, as an interpretative aid, does not offend the parol evidence rule, which excludes evidence of the parties' subjective intentions and precludes considering evidence outside the words of the contract that would result in varying the contract in some manner. See detailed summary under ETA – s. 153(1). ...

. … The cost of a modification of the restrictions of the rights that a landowner has with respect to the use of land is a part of the cost of the land. …Density rights have to do with what the owner can do with the land. … It requires something of a leap of faith to claim capital cost allowance under Class 3 on a building that does not exist and may never exist. ...