Search - 阿里拍卖 司法拍卖

Although many of the receipts issued by the Apple stores had missing, scratched, fictitious or unreadable names for the buyers (as agents of Lohas), for the transactions where a bank draft was issued to a buyer, a “memo prepared by Lohas showed the name of each buyer, the iPhones purchases, the tax and the commissions paid” (para. 147) However, for the transactions that Lohas paid in cash, the memo did not always indicate the name of the buyers – and, as noted, the receipts were defective- so that ITCs were denied for these, but not for those where the names were noted in the memo. ...

. … Should the Minister decide to exercise her discretion under subsection 207.06(1) of the Act to cancel the Appellant’s liability in respect of the inadvertent deposit of $40,000 to his TFSA on the night of July 21, 2016, such cancellation would find ample support on the extraordinary facts of this case. ...

The Queen, 2019 TCC 265-- summary under Ownership Summary Under Tax Topics- General Concepts- Ownership markers of possession, use and risk applied in ascertaining beneficial ownership Before finding that there had been a transfer to the taxpayer of ½ of the beneficial ownership of the family home for s. 160 purposes from her husband (rather than her having been the full beneficial owner all along), MacPhee J adopted (at para. 24) a previous judicial formulation of the concept of beneficial ownership, viz: The primary attributes of beneficial ownership include possession, use and risk. ...

To address increasing mobility issues of his wife, the taxpayer replaced these with a deck with a 5-foot wide stairway and aluminum railing – and claimed the $10,000 home accessibility tax credit. ...

Krumm, IAC and its agents could each be considered to be a tax shelter “promoter”, as defined in subsection 237.1(1) …. ...

The Queen, 2020 TCC 6-- summary under Subsection 163(2) Summary Under Tax Topics- Income Tax Act- Section 163- Subsection 163(2) taxpayer not subject to penalty where its CPA firm made inexplicable errors D’Auray J found that a one-man corporation that had a business of constructing (through using third-party contractors) and selling about 10 or 20 new homes per year had not been demonstrated by the Crown to be liable for gross negligence penalties for failure to report in its GST returns two of the home sales it made in the 2 ½ year audit period. ...

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. ...

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. ­­­­­­­­­­­­­­­­­­­ ...