Search - 阿里拍卖 司法拍卖

. … Too many of the expenses incurred in making the sales were missing for it to be possible to state that Oldcastle realized a profit on the sale…. ...

In finding that the appellant had continued to be a “registrant,” so that ss. 171(3) and 200(2) did not apply, Favreau J referenced s. 141.1(3) and stated (at paras 57- 60, TaxInterpretations translation): The sale of equipment following the cessation of normal daily activities is … part of what the ETA terms "commercial activity". ...

. … Words and Phrases credit note ...

However 15 months later, CRA vacated the s. 55(2) assessment of 8231 for reasons that are not explained – so that the only outstanding s. 55(2) assessments were of the corporations (807 and 810) acquired by the purchasers. ...

. … The use of the word “habituelle” in French…makes it even more clear and certain that the use of the word “primary” to qualify “place of residence” in English is not to suggest that the new housing rebate is only available to those who also have at least a second home also used as a place of residence. ...

CRA asserted that the competent authority proceedings did not result in binding agreements between Sifto Canada and CRA and, even if they did, they did not fix the arm’s length transfer price – so that CRA was not only authorized, but was required, by the ITA to issue the post-audit reassessments once in possession of the new audit information. ...

. … It is true that here there was an 8 1/2” x 14” on‑the‑shelf sign…[but] Costco was merely advertising the discount. ...

. … CRA’s analysis arrived at about 65:35. He also noted (at para. 16): Since they are co-parenting with shared parental responsibilities and the school and daycare are aware of the precise terms of their divorce order, it might be more appropriate to consider seven hours of each school day as 50:50 [rather than 100% to the mother]. ...

Miller J found (at para 32): … It is my view that in a GAAR appeal, draft documents prepared in the context of a taxpayer’s audit or considered by officials involved in or consulted during the audit and assessment of the taxpayer should be disclosed. ...

The Funds argued that they were receiving an exempt financial service from Funding Corp – so that this arrangement in effect eliminated the GST or HST on the portion of the management fees that was assigned to Funding Corp. ...