Search - 阿里拍卖 司法拍卖

. … The most that can be said is that he intermittently stayed at the work site and did not even have the means of establishing a “residence” within the meaning of section 110.7 of the Act, even though that was his intention. ...

Following the realization shortly thereafter by Newco of a taxable capital gain and recapture of depreciation on a sale of the building, Newco increased the adjusted cost base to Holdco of its shares by effecting a series of s. 84(1) dividends (including a capital dividend) – following which the individual sold his shares of Holdco to a third party for a sale price based on the amount of cash sitting in Newco. ...

CRA denied the taxpayer’s request four years later for a refund of this amount on the grounds that this request had not been made within the required three-year period – and in the resulting 2014 reassessment it in fact denied some deductions/credits that had been initially allowed in its 2009 assessment. ...

In those cases, denying the defence would give rise to the concerns mentioned by Justice Iacobucci at para 44 of First Vancouver – it "would have a general chilling effect on commercial transactions.” ...

This arrangement appears to be more comprehensive than the one featured in Costco [2009 TCC 134] …. ...

…At its most basic level …, the benefit that Visa offered CIBC was cost saving and logistical simplification. ...

(t) of “financial service,” Rossiter CJ first found that the services of Visa were “quintessentially administrative in nature” so as to come within s. 4(2)(b) of the Regulation, and then rejected the suggestion that Visa was a broker, stating (at para 128): The definitions of a broker … give the impression of someone that actively engages in commercial activity, such as negotiating, buying and selling, on behalf of a principal. ...

. … Prior to SOCAN coming into existence, a music composer’s client paid the composer directly for the services rendered in writing and recording tracks/cues for television episodes. ...

In May 2008, the taxpayer arranged for the ½ co-ownership interests to be transferred to her. ...

In finding that the appellant did not satisfy the documentary requirements for claiming input tax credits, Favreau J stated (at paras. 58-59, TaxInterpretations translation): The appellant thus did not have in hand the particulars prescribed by the Regulation at the time that it claimed the ITCs as required by paragraph 169(4)(a) …. ...