Search - 阿里拍卖 司法拍卖

.' In my view, those words describe the … Society. The supervision is provided by the conductor of the band or choral group. ... Although the … Society is a registered charity, the right of its members to the supervision of a conductor in their recreational activity falls within paragraph 2(j) of Part VI Schedule V. ...

. … Neither the applicant, nor Mr Lewski on her behalf, took any step to disclaim the distribution before 15 December 2015. In these circumstances … we consider the conclusion that the applicant was taken to have had knowledge of, and to have accepted, the gifts before 15 December 2015 to be consistent with the cases and principles discussed above. ...

. … [A] requirement certainly cannot be used to disguise a seizure made without judicial authorization. In such circumstances, section 8 of the Charter … was infringed by the ARQ…. ...

In rejecting this position, Vaillancourt JCQ stated (at paras. 32-34, TaxInterpretations translation): The plaintiff … recognized having received the amounts from Groupe Norbourg without any right thereto, which constitutes an insurmountable obstacle to her argument that she paid the interest on a loan. … [T]he plaintiff paid the interest to RSM for the sole purpose of buying time to repay the receiver the sums which she had received without any right thereto. ...

. … It was not for the ARQ to find the error. The burden was on the taxpayer to submit accurate tax returns. It was the return of the taxpayer according to which the properties in question were included in Class 12 which, if so established, was the source of the error of fact by the ARQ. … It would be contrary to the interests of justice for the ARQ to be precluded from a defence based on the facts, which were erroneously presented by the plaintiff, even though the file is at the stage of an appeal from the notice of assessment. ...

Before dismissing the taxpayer’s appeal, Lafrenière JCQ rejected these submissions, stating (at para. 17, TaxInterpretations translation): [T]he exception provided in Articles 93.1 to 93.3 … applies without regard to whether the disposition is voluntary or involuntary, and also applies independently of whether or not there was a wish to dispose of the underlying land. He also quoted (at para. 17) with approval similar findings in 9136-6872 Québec: [16] In my opinion, it would be incorrect to argue that paragraph [13(21)](b) does not apply if the land is never sold or if an appellant has no intention of selling it, because no taxpayer knows at what particular time he or she will dispose of land. … [18] Paragraph 13(21.1)(b) merely provides that the land must not be disposed of in the same taxation year as the building. ...

In confirming the confirmation below of the ARQ’s denial of recognition of his share of SEC losses, the Court stated (at paras. 4-5, 7, TaxInterpretations translation): The judge of first instance … highlighted that the quantity and quality of the transactions and agreements presented in evidence were negligible in relation the ongoing activities of a company whose joint fund amounted to $5,273,272. … The judge of first instance also found that the documents produced in evidence that the appellant did not support his position that he had acted as agent or mandatary of the limited partnership. ...

In affirming this finding, the Full Court stated (at paras. 64-65): What bound the respondents to dispose of their shares and interests in Talison Lithium was not the entry into a contract of sale overseas but the convening of the scheme meeting, the approval at that meeting of the scheme of arrangement, the approval of that scheme by the Court, and the lodging of the order of the Court with the Australian Securities and Investment Commission …. ... That arrangement took place in Australia, and accordingly, because the scheme was the “proximate” origin of the profits earned, and because of the other connections with Australia summarised by the primary judge … including the location of the mine in Western Australia, those profits had a source in Australia. ...

. … We agree with the government that Article 26A merely facilitates collection of an already existing debt. … In also rejecting Retfalvi’s submission that Art. 26A required House-originated implementing legislation, and before dismissing his appeal, she stated (at p. 17): Article 26A relies on each country’s existing tax laws and procedures for assessment and collection. ...

. … Where a parent company merely “influences” the subsidiary, CMC remains with the board of the subsidiary. ... The FTT found that Mr Lanes did not influence the Jersey directors …. ...