Search - 阿里拍卖 司法拍卖

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. … Thus, even if the obiter dicta is binding, it is not determinative of these Appeals. ...

. … The provision by the customer of the loan was the consideration for both the payment of interest and the provision of the banking services. ...

The Queen, 2018 TCC 3, aff'd on s. 18(1)(a) grounds 2019 FCA 36-- summary under Total Charitable Gifts Summary Under Tax Topics- Income Tax Act- Section 118.1- Subsection 118.1(1)- Total Charitable Gifts payment relieving of a correlative contractual obligation was not a gift The corporate taxpayer agreed with the City of Chandler that it would no longer use any loan repayment proceeds received by it from a City-owned corporation- that had failed in an costly attempt to restart a paper mill close to the City – to invest in a prospective replacement economic-development LP to be sponsored by the City, but would instead make a “gift” of the loan repayment proceeds (which ended up totalling $9.3 million) to the City. ...

. … As I construe subsection 84(3), a corporation is deemed to have paid a dividend at the time of the acquisition of its shares and, even if the consideration for the shares acquired is payable over a considerable period of time, it must, for the purposes of income tax law, be regarded as being payable at the time of the acquisition. ...

. … Seeking “a sensible, practical and common sense result” is quite different from dispassionately and objectively examining the text, context and purpose of the legislation in issue; the latter turns on the nature of the legislation while the former depends on the nature of the judge. ...

Smith J found that (at para 70): … I conclude that the Appellant did not cease to be a de jure director (MacDonald v. ...

The Queen, 2018 TCC 48-- summary under Paragraph 39(1)(c) Summary Under Tax Topics- Income Tax Act- Section 39- Subsection 39(1)- Paragraph 39(1)(c) The market for the business of the taxpayer’s corporation (“Radio Progressive “) of selling and repairing radio telecommunication equipment had virtually disappeared by 2007, so that from that time on, it did not make any sales, and essentially its only activity related to the efforts of the taxpayer (Mr. ...

In rejecting this position, Paris J referred to Article 1417 of the Civil Code (“A contract is absolutely null where the condition of formation sanctioned by its nullity is necessary for the protection of the general interest”), and stated (at paras. 26, 34, TaxInterpretations translation): On numerous occasions, the jurisprudence has reiterated that a purpose which is contrary to the public order and which contravenes a penal provision, in the current case, of the Criminal Code, engages the absolute nullity of the contract in accordance with Article 1417 …. ...

In rejecting this position, Paris J referred to Article 1417 of the Civil Code (“A contract is absolutely null where the condition of formation sanctioned by its nullity is necessary for the protection of the general interest”), and stated (at paras. 26, 34, TaxInterpretations translation): On numerous occasions, the jurisprudence has reiterated that a purpose which is contrary to the public order and which contravenes a penal provision, in the current case, of the Criminal Code, engages the absolute nullity of the contract in accordance with Article 1417 …. ...