Search - 阿里拍卖 司法拍卖

. … I can see no reason why that which is legitimate and proper outside the insolvency context should be viewed differently within it. ...

. … The US connections required by s.269B are limited to a) stapling of more than 50% by value of the foreign corporation's shares to those of a domestic corporation, and b) direct or indirect ownership as to 50% or more by US persons. ...

They accomplished what section 160 sought to prevent – its application, they defeated its underlying rationale, and they circumvented its application. ...

Furthermore, since in light of s. 251(6)(b) “a marriage ends on the death of one of the individuals … [t]o have the same rules apply to individuals in a common-law partnership, that relationship would also have to cease upon the death of one of the partners” (para. 44). ...

Before allowing the taxpayers appeal, Yuan J, stated (at para. 41): I have difficulty imagining what better evidence the CRA could reasonably expect an applicant to produce as proof of filing where the application was submitted by regular mail …. ...

The test is whether … may one say that the building was renovated sufficiently enough that all or substantially all of the building has been removed or replaced: Camiré v. ...

Agence du revenu du Québec, 2025 QCCQ 1127-- summary under Subsection 45(1) Summary Under Tax Topics- Income Tax Act- Section 45- Subsection 45(1) the conversion of apartment buildings to condo units did not trigger a change of use – and that CAE rather than IT-218R would apply re change of use In 1981, the taxpayers (10 individuals), acquired as co-owners two adjoining rental buildings containing a total of 82 apartments, with their respective undivided interests in such properties ranging from 2.27% to 29.2%. ...

After this granting of an earlier effective registration date, 353 then refiled the returns for the initial three quarters, and CRA then promptly assessed 353’s returns – but apparently not the initial three quarters. ...

In rejecting this position, Monaghan JA noted (at para. 303) that s. 56(1) provides that "there shall be included in computing the income of a taxpayer for a taxation year" the amount described in that section, including "amounts required by section 146 in respect of a [RRSP] … to be included in computing the taxpayer's income for the year," and s. 146(10), in turn, stated that where an RRSP acquired a non-qualified investment, the acquisition date value "shall be included in computing the income for the year of the taxpayer who is the annuitant. ...

Smith J indicated (at para. 522) that: [T]he T3GR Return was the prescribed form intended by CRA to meet the filing requirements of RRSP trustees pursuant to paragraph 150(1)(c) and subsection 207.2(1) of the Act and section 204 of the Regulations and … it was intended as a streamlined process for the reporting of group RRSPs involving hundreds of thousands of plans under one specimen plan. ...