Search - 阿里拍卖 司法拍卖

. … As a result of subsection 204.3(2), the limitation periods in subsection 152(3.1) apply to Part X.1, with modification. ...

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. … Although Mr. RF works in the construction industry, this does not deprive him of the right to acquire and sell his principal residence if circumstances make it unavoidable or desirable, even if the transactions occur over a relatively short period of time. ...

Canada, 2016 FCA 304-- summary under Investment Contract Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(11)- Investment Contract pointless to determine whether an instrument is debt for purposes of whole Act The Federal Court of Appeal dismissed the Barejo appeal – but on the grounds that the Rule 58 question posed to the Tax Court was whether the “notes” in question were debts for purposes of the Act rather than for purposes of s. 94.1 thereof. ...

Canada, 2016 FCA 299-- summary under Section 8.1 Summary Under Tax Topics- Statutory Interpretation- Interpretation Act- Section 8.1 Tax Court can review validity of contract in reviewing assessment Before indicating that it was unnecessary to pass on whether it was beyond the competence of the Tax Court to declare that options were invalid under Quebec law, Noël CJ stated (at para. 42, TaxInterpretations translation): [T]he role of the TCC, when confronted with an argument based on nullity in the context of an appeal under the ITA, cannot be assimilated to that of a Superior Court which has the power to “declare” a contract to be a nullity for all purposes pursuant to section 33, 35 and 142 of the Code of Civil Procedure … (see in comparison Markou v. ...

In finding that the appellant had continued to be a “registrant,” so that ss. 171(3)(b) and 200(2) did not apply, Favreau J referenced s. 141.1(3) and stated (at paras 57- 60, TaxInterpretations translation): The sale of equipment following the cessation of normal daily activities is … part of what the ETA terms "commercial activity". ...

. … It is in the vineyard where most of the employees are hired, where most of the equipment is required and used, where the labour expenses are the highest, and where the majority of the acreage is used. ...

Miller J found that the quoted definition of " freight transportation service" required that the property be carried by some mode of transport such as a vehicle, ship or rail car and that merely driving a car did not qualify as transporting it, stating (at para. 29) that: [T]he vehicle cannot be both the personal property and the means of carrying it at the same time. ...

Green, 2017 FCA 107-- summary under Paragraph 111(1)(e) Summary Under Tax Topics- Income Tax Act- Section 111- Subsection 111(1)- Paragraph 111(1)(e) upper-tier LP not required to compute income and therefore not subject to s. 111(1)(e) CRA considered that business losses incurred by lower tier partnerships (the PSLPs) were deemed to be limited partnership losses of an upper-tier LP (MLP) – which meant that they were effectively trapped in MLP given that s. 111 (and, thus, the ability to deduct limited partnership losses under s. 111(1)(e)) was only available to a taxpayer and not to a partnership such as MLP. ...

. … [T]he words “with all due dispatch”, as set out in section 152(1)…, have no bearing on this analysis. ...