Search - 阿里拍卖 司法拍卖

As … noted in City of Calgary, such supplies are parts or components of the single overall supply of electricity. ...

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 Appellant continued to work outside the home after marrying CC and had no special training qualifying her to care for CC in a manner beyond the level of care that might be expected of any spouse. ...

He concluded (at para. 27): This is the type of situation … wherein a shareholder receives draws on the shareholder loan account throughout the year and then a dividend determination is made at some point for the year. ...

II, s. 9, Smith J stated (at para. 69, TaxInterpretations translation): [I]t is not sufficient … that the appellant's website inform the consumer of the need for a valid prescription. ...

The documents framed the optional term extension “as a separate pursuit … separate and distinct from the electricity supply contract” (para. 93). ...

Since section 37 does exist, however, they are also SR & ED expenditures and are deductible as such and are entitled to whatever beneficial treatment is accorded to them by section 37. ...

In finding that the appellant was making taxable supplies, D’Arcy J first stated (at para. 88) that it was “providing something,” which was “the service of collecting, recycling and/or safely disposing of the MHS Waste (the “Recycling Services”),” and that (para. 89) it “provide[d] the Recycling Services to the persons who physically possessed the MHS Waste prior to its collection by the Appellant and to the MHSW Stewards, who … had a statutory obligation to incur the cost of collecting and recycling the MHS Waste.” ...

Spiro J further stated (at para. 22): The … fact is that none of the $8,000 support amount payable by Dr. ...

In finding that the taxpayer's evidence did not make out a prima facie case to demolish the assumptions of fact underlying the Minister's choice of a 1.013% discount rate, so that the taxpayer's appeal was dismissed, Boyle J made the following findings and observations: The appropriate approach under ss. 247(2)(a) and (c) was "to follow the structure of the RSA that the McKesson Group chose to enter into…and consider whether the terms and conditions which affect the Discount Rate pricing differ from what arm's length terms and conditions would be expected to provide" (para. 270) – rather than to look at the pricing that would have applied to a different structure, e.g., a sale of the receivables on a recourse basis, with such recourse secured by a reserve (para. 166). ... The component of the discount rate to reflect potential bad debt losses should be reduced so as to only reflect the historic loss performance of the taxpayer's receivables pool (of 0.04%) plus a 50% to 100% premium over this (increasing this component to 0.06% to 0.08%) to reflect a risk of this experience deteriorating (paras. 306, 311-312) – rather than using a much higher imputed loss rate based on the proposition that the sales customers did not have bond ratings ("I can not reasonably conclude that a company that does not have a bond rating can be assumed to be hiding a bad implicit rating from the public" (para. 298, see also para. 245).) ...