Search - 阿里拍卖 司法拍卖

The Queen, 2019 TCC 5 (Informal Procedure)-- summary under Paragraph 125(3)(b) Summary Under Tax Topics- Income Tax Act- Section 125- Subsection 125(3)- Paragraph 125(3)(b) SBD denied because no agreement made In confirming the correctness of a reassessment of a corporation (Newgate) denying it the small business deduction, D’Auray J stated (at paras 36-37): … At trial, it was shown that the effect of the underlying reassessment was to disallow Newgate’s small business deduction… because Newgate and its associated corporation, 807 BC Ltd., made inconsistent filings…. ...

The Queen, 2019 TCC 254, aff'd 2022 FCA 66-- summary under Subsection 82(1) Summary Under Tax Topics- Income Tax Act- Section 82- Subsection 82(1) payment was dividend even though no declaration In finding that a corporation should be treated as having paid dividends to its shareholder, so that CRA validly assessed the shareholder under s. 160 for a tax debt of the corporation, even though no dividend had been declared, and the only evidence of the payment of a dividend was the cash movements and the corporation’s subsequently-fired accountant issuing T5 slips to the taxpayer, MacPhee J stated (at para. 23): [A] reported dividend, even if not in compliance with the provincial statute, remains valid for tax purposes …. ...

The Queen, 2019 TCC 265-- summary under Land Summary Under Tax Topics- General Concepts- Fair Market Value- Land FMV of home potentially reduced by spouse continuing to live there After finding that s. 160 applied on the basis that ½ of the beneficial ownership of the family had been transferred for nominal consideration to the taxpayer by her husband, a tax debtor, MacPhee J also noted (at para. 34) that “it could be argued that the value of what was transferred by Mr. ...

.), Masse DJ allowed a significant portion of the claimed expenses – but disallowed others, for example, only allowing the expenses of the taxpayer’s cell phone but not his two land lines. ...

. … ...

The King, 2024 TCC 19 (Informal Procedure)-- summary under Paragraph (e) Summary Under Tax Topics- Income Tax Act- Section 122.6- Eligible Individual- Paragraph (e) refugee claimants were ineligible Bocock J held that he was bound by the decision in Almadhoun that as a matter of statutory interpretation of s. 122.6 – eligible individual- s. ...

The King, 2024 TCC 125-- summary under Paragraph 141.02(31)(f) Summary Under Tax Topics- Excise Tax Act- Section 141.02- Subsection 141.02(31)- Paragraph 141.02(31)(f) s. 141.02(31)(f) is merely confirmatory of normal taxpayer onus Before going on to find that the Minister’s pre-approval of an ITC calculation methodology under s. 141.02(20) did not preclude subsequent reassessments to deny the zero-rated status of supplies which had been assumed under such methodology, Smith J stated (at para. 45): I find that paragraph 141.02(31)(f) merely confirms that a financial institution has the onus of establishing that the “particular methods (…) were used consistently” during the fiscal year at issue. ...

Also in March 2005, 9149 redeemed the Class A common shares for their PUC and ACB of $347,848 (so that no deemed divided or capital gain resulted) and redeemed approximately ¾ of the Class B preferred shares, giving rise to a deemed dividend and capital loss of $196,506 to the taxpayers. ... At the end of 2008, 9149 redeemed the (¼) balance of the Class B preferred shares for $69,000, giving rise to a deemed dividend and capital loss to the taxpayers of $69,000 and $73,112. ...

. … IPL2 stands for the proposition that...gross income from a source in a particular location must be reduced by any deduction that may reasonably be regarded as applicable to that source. ... It seems unlikely that the tax sparing provision was intended…to operate to shelter not only Brazilian interest income from Canadian tax, but income from other sources unrelated to Brazil as well. … After noting (at paras. 69-70) that: Article 23B of the 1977 OECD Model....uses the phrase “that part of the income tax… which is attributable…to the income…which may be taxed in that other state.” ...

. … What it supplies is the agreement to use the Annual Resort Fees to fund its operations. … This…is the supply of something other than property. ...