Search - 阿里拍卖 司法拍卖

He noted (at para. 33) that the UK domestic deeming provision instead only had a limited purposes, which was to give the diver access to more generous deductions from income, and stated that to apply this limited “deeming provision … so as to alter the meaning of terms in the Treaty with the result of rendering a qualifying diver immune from UK taxation would be contrary to its purpose.” ...

Canada, 2020 FCA 97-- summary under Subsection 246(1) Summary Under Tax Topics- Income Tax Act- Section 246- Subsection 246(1) the Cirque du Soleil’s bearing most of the $41.8M cost of a space trip for its controlling shareholder gave rise to a shareholder benefit The founder and controlling shareholder of Cirque du Soleil, had been found by the Tax Court to have received a taxable benefit under s. 15(1) (or alternatively, under s. 246(1)) equaling approximately 90% of the $41.8 million cost of sending him on a trip to the international space station (ISS) in September and October 2009, given that the cost was borne by his family holding company and then largely passed through to the top operating company (“Créations Méandres “) in the Cirque du Soleil group, but with there being a matching contribution of capital by the holding company to Créations Méandres so that independent shareholders would not bear any of the cost of the trip. ...

In rejecting the ARQ’s submission that it was contrary to judicial comity and an abuse of process for the same transactions to be appealed respecting QST to the Court of Quebec (and before going on to grant the appellants’ appeals in part), Choquette JCQ stated (at paras. 22, 24 and 25, TaxInterpetations translation): With respect, the judgment of the TCC is a transcript of the recording of the oral judgment and does not reveal the facts submitted or the Court's considerations …. ...

He testified that “he never developed a strong sense of belonging to Quebec” and that “his best friend … lived in Ontario” (para. 43). ...

Spiro J set the stage by noting (at para. 14) that “In order for the Minister to assess a policyholder under … subsection 148(1)… the “adjusted cost basis” of the policy to the policyholder immediately before its disposition must be determined,” and by stating (at para 25): The courts have consistently held that unless the Minister’s assumptions of fact are sufficient to support the assessment under the relevant legislation, the onus does not shift to the taxpayer. ...

. … There is no evidence that any GST/HST remittances were diverted to assist with the business activities. ...

. … He bills the Government of Ontario for such [medical] services in his own name. ...

., 2020 FCA 125-- summary under Subsection 152(4) Summary Under Tax Topics- Income Tax Act- Section 152- Subsection 152(4) nil assessment not subject to 3-year limitation in s. 152(4) In finding that a nil assessment was valid for s. 164(1) purposes notwithstanding that it had been issued (in 2010) more than three years after the previous (2003) reassessment, Noël CJ stated (at para. 58): Subsection 152(4) gives the Minister the power to “notify in writing any person […] that no tax is payable for the year”. ...

After March 21, 2016, the object, spirit and purpose of the Reduction Provision, as amended, was to refer to the adjusted cost basis of a policyholder’s interest in the particular policy in order to determine the amount that could be added to the capital dividend account of a corporate beneficiary, even where that beneficiary was not the policyholder. ­­­­­­­­­­­­­­­­­­­ ...

In this regard, he stated (at para. 47, citing Wild): [I]t is now established that the modification of tax attributes, such as an increase in a taxpayer’s CDA, does not give rise to a tax benefit unless and until a capital dividend is paid out of that account to a recipient capable of benefiting from its tax-free character …. ...