Search - 2002年 抽纸品牌 质量排名

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Decision summary

S & C Ross Enterprises Ltd. v. The Queen, 2002 DTC 2078 (TCC) -- summary under Personal Services Business

S & C Ross Enterprises Ltd. v. The Queen, 2002 DTC 2078 (TCC)-- summary under Personal Services Business Summary Under Tax Topics- Income Tax Act- Section 125- Subsection 125(7)- Personal Services Business The sole shareholder ("Ross") of the taxpayer served as the CFO of a Canadian company ("Clearly Canadian") and also performed services on behalf of the taxpayer for Clearly Canadian. ...
Decision summary

Royal Bank of Scotland PLC v. Customs & Excise Commissioners, [2002] BTC 5280 (Court in Session (Inner House)) -- summary under Recipient

Customs & Excise Commissioners, [2002] BTC 5280 (Court in Session (Inner House))-- summary under Recipient Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Recipient The Appellant, which was entitled to issue its own bank notes, entered into a reciprocal agreement with other banks pursuant to which it was entitled to a flat fee per transaction when customers of the other banks were issued bank notes of the Appellant (or bank notes of the Bank of England) through ATMs of the Appellant. ...
Decision summary

Pope & Ors v. R & C Commrs., [2012] UKUT 206 (Tax and Chancery Chamber) -- summary under Paragraph 12(1)(c)

Pope & Ors v. R & C Commrs., [2012] UKUT 206 (Tax and Chancery Chamber)-- summary under Paragraph 12(1)(c) Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(1)- Paragraph 12(1)(c) The son of the taxpayers (Mr and Mrs Pope), who was the beneficiary of a life insurance policy which he had purchased on his own life, was abducted in Angola by rebels in 1998. ... In 2002, the provider paid the £100,000 principal amount insured, plus an additional amount of £36,425.97. ... The payment had clearly been made as compensation for the deprivation between 1998 and 2002 of the principal amount. ...
Decision summary

Pope & Ors v. R & C Commrs., [2012] UKUT 206 (Tax and Chancery Chamber) -- summary under Subsection 104(13)

Pope & Ors v. R & C Commrs., [2012] UKUT 206 (Tax and Chancery Chamber)-- summary under Subsection 104(13) Summary Under Tax Topics- Income Tax Act- 101-110- Section 104- Subsection 104(13) The son of the taxpayer, who was the beneficiary of his own life insurance policy, likely died in 1998 when he was abducted by Angolan rebels, but this was never conclusively established. In 2002 the insurer paid the £100,000 principal amount insured to the taxpayer, plus an additional amount £36,425.97, which the Tribunal determined was interest. ...
Decision summary

Bouchan v. Slipacoff, 2010 ONSC 2693 -- summary under Rectification & Rescission

Slipacoff, 2010 ONSC 2693-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission two-year limitations period The defendant and plaintiff held shares in an incorporated dental practice. ... Section 5 of Ontario's Limitations Act, 2002 essentially commences the limitations period from when the applicant knows or ought to know of a potential claim against the defendant. ...
FCA (summary)

Canada v. Canadian Pacific Ltd., 2002 DTC 6742, [2002] 3 F.C. 170, 2002 FCA 98 -- summary under Transaction

., 2002 DTC 6742, [2002] 3 F.C. 170, 2002 FCA 98-- summary under Transaction Summary Under Tax Topics- Income Tax Act- Section 245- Subsection 245(1)- Transaction an aspect of a transaction is not a transaction The Crown argued that CP's act of denominating the debentures in Australian dollars was in and of itself a transaction and that it amounted to an “arrangement” under the s. 245(1) definition of "transaction"- and then argued that such "separate transaction", namely the designation of borrowing in Australian dollars, was entered into solely for tax purposes. ... …If this argument was correct, the Crown could allege that the tax planning component of any transaction amounted to an event or arrangement constituting a "separate transaction". In other words, any action taken to obtain a tax benefit would be an avoidance transaction and there would never be an occasion to determine the primary purpose of a transaction. The words of the Act require consideration of a transaction in its entirety and it is not open to the Crown artificially to split off various aspects of it in order to create an avoidance transaction. ...
SCC (summary)

Stewart v. Canada, 2002 DTC 6969, 2002 SCC 46, [2002] 2 SCR 645 -- summary under Business Source/Reasonable Expectation of Profit

Canada, 2002 DTC 6969, 2002 SCC 46, [2002] 2 SCR 645-- summary under Business Source/Reasonable Expectation of Profit Summary Under Tax Topics- Income Tax Act- Section 3- Paragraph 3(a)- Business Source/Reasonable Expectation of Profit no reasonable expectation of profit test if no personal element There was no evidence that the taxpayer had acquired condominium rental units for his personal benefit. ... The purpose of this test is to distinguish between commercial and personal activities, and where there is no personal or hobby element to a venture undertaken with a view to a profit, the activity is commercial, and the taxpayer's pursuit of profit is established. We emphasize that this "pursuit of profit" source test will only require analysis in situations where there is some personal or hobby element to the activity in question.... ... As such, a source of income by definition exists, and there is no need to take the inquiry any further. In summary, the issue of whether or not a taxpayer has a source of income is to be determined by looking at the commerciality of the activity in question. ...
TCC (summary)

Francis & Associates v. The Queen, 2014 DTC 1146 [at at 3468], 2014 TCC 137 (Informal Procedure) -- summary under Subparagraph 152(4)(a)(i)

Francis & Associates v. The Queen, 2014 DTC 1146 [at at 3468], 2014 TCC 137 (Informal Procedure)-- summary under Subparagraph 152(4)(a)(i) Summary Under Tax Topics- Income Tax Act- Section 152- Subsection 152(4)- Paragraph 152(4)(a)- Subparagraph 152(4)(a)(i) taxpayers held to standard of wise and prudent law partner A review of a law firm's accounts in 2005 by its external accountant revealed various substantial errors for the 2002 to 2004 years. ... In finding that the 2002 and 2003 years could be reassessed beyond the normal reassessment period, Bocock J stated (at para. 24): [T]he Appellants' conduct was not consistent with that of a wise and prudent law partner. ...
Decision summary

Cussens & Ors v Brosnan, ECLI:EU:C:2017:881:Case C-251/16, [2017] BVC 61 -- summary under Subsection 274(4)

On 3 April 2002 those two leases were extinguished by mutual surrender of the lessees, and the taxpayers therefore recovered full ownership of the properties. In May 2002 the taxpayers sold all the properties to third parties. Under section 4(9) of the VAT Act, no VAT was payable on those sales, as the properties had previously been the subject of a first supply on which VAT was chargeable, when the long lease was granted. ... …[T]he leases had no commercial reality and were entered into with the aim of reducing the VAT liability on the sales of immovable property which they envisaged carrying out subsequently. ...
TCC (summary)

Francis & Associates v. The Queen, 2014 DTC 1146 [at at 3468], 2014 TCC 137 (Informal Procedure) -- summary under Subparagraph 20(1)(p)(i)

Francis & Associates v. The Queen, 2014 DTC 1146 [at at 3468], 2014 TCC 137 (Informal Procedure)-- summary under Subparagraph 20(1)(p)(i) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(p)- Subparagraph 20(1)(p)(i) subsequently discovered bad debts not claimable; unbilled disbursements deductible under s. 9 A review of a law firm's accounts in 2005 revealed that accounts had been rendered in 2002, 2003 and 2004 which were uncollectible and which had not been written off. The appellant partners filed revised tax returns for the 2002 to 2004 taxation years in 2007, in which they claimed related bad debt deductions for those years, with the Minister apparently disallowing those deductions in resulting 2007 reassessments and in further varied reassessments made in 2012. ...

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