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Article Summary
Lucie Lamarre ACJ, Isida Ranxi, "Taxpayer Rights and Voluntary Compliance: The Example of the Canadian Judiciary", Tax Notes International, 3 October 2016, p. 61 -- summary under Evidence
. … [T]he appearance of fairness has another aspect — that is, how the proceedings appear to the unrepresented party. ... " [fn 64: [2002] 2 CTC 2405, at para 17 (TCC), cited with approval by the Federal Court of Appeal in Burton v The Queen, 2006 DTC 6133, at paras 12-13.] ...
Article Summary
Brian Mustard, Sam Maruca, Charles Thériault, Richard Tremblay, "Transfer Pricing: What Are 'Reasonable Efforts,' and When should Penalties Apply?", Canadian Tax Foundation, 2015 Conference Report, 32:1-33 -- summary under Subsection 247(3)
" … In Royal Oak Mines [[1996] 1 S.C.R. 369], the Supreme Court of Canada concluded that "reasonable effort" is an objective standard that can be assessed by reference to "comparable standards and practices within the particular industry." … Rossiter v. Chiasson, [1950] OWN 265 (HCJ)…[stated] the party need not "go to absurd, whimsical or unwarranted lengths" since "reasonable" means " 'logical,' 'sensible' and 'fair.' " … Crown Employees [1997 CarswellOnt 6197] explicitly held that reasonable efforts does not mean "all efforts. ... Appropriateness of avoiding penalties where reliance on expert reports (p. 32:18) [In DHL Corporation and Subsidiaries v CIR, 285 F. 3d 1210 (9th Cir. 2002); aff'g, in part, rev'g, in part, and remanding 76 TCM 1122 (1998)] the taxpayer ("DHL") hired Bain & Co., Inc. ...
Article Summary
Robert Kopstein, Rebecca Levi, "When Should the Courts Allow Reassessments Beyond the Limitation Period", Canadian Tax Journal, (2010) Vol. 58, No. 3, 475-527 -- summary under Subparagraph 152(4)(a)(i)
The Queen, 2002 DTC 1217 (TCC), Edible What Candy Corp. v. R. [2002] 1 GSTC 33 (TCC)] The taxpayer withheld facts from the tax preparer that would have affected the filing position taken, or withheld the existence of the transaction entirely. ... The authors proceeded to consider what a realistic possibility means (at p. 518): In order to support a "realistic possibility" opinion, there must be a reasonable basis for the filing position that is taken. … we believe that a reasonable basis exists where there is some authority for the filing position taken, and no obvious authority to the contrary. ...