Search - 2002年 抽纸品牌 质量排名

The Queen, 2002 DTC 1749 (TCC)-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt funds to support cheques Miller T.C.J. noted that with respect to the situation where the taxpayer, which owed approximately $60 million in accrued interest, paid $60 million to the creditor at the same time that the creditor paid $60 million to the taxpayer as an addition to the advances owing by the taxpayer, that he had difficulty identifying any moment in time at which the taxpayer did not owe $60 million to the creditor. ...

The Queen, 2000 DTC 2372 (TCC), aff'd 2002 DTC 6740, 2001 FCA 393-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development Bonner T.C.J. accepted (at p. 2382) the evidence of the Crown's expert that the cost incurred by a lottery ticket marketer in developing an information system employing object-oriented architecture did not represent SR&ED because "the project used commercially available products and services, and current information systems development methodologies and practices throughout". ...

Toronto Refiners & Smelters Ltd. v. The Queen, 2001 DTC 876 (TCC), aff'd 2003 DTC 5002, 2002 FCA 476-- summary under Adjusted Cost Base Summary Under Tax Topics- Income Tax Act- Section 54- Adjusted Cost Base The taxpayer agreed to transfer its Toronto property to the City of Toronto with the compensation to be determined (under section 31 of the Expropriations Act) by the Ontario Municipal Board. ...

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. ...

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. ...

The Queen, 2019 TCC 6-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission a rectification judgment was “justifiably obtained” and, therefore, followed for tax purposes On April 15, 2002, the taxpayer signed an agreement for the purchase of shares of a real estate corporation (“Quatre Saisons”) that stated that the purchase price was to be satisfied by the payment to the vendor (“Placeval,” a corporation owned by a Mr. ... Before granting the taxpayer’s appeal from the assessment, Favreau J stated (at paras. 55, 59-60, 62): [T]he judgment of the Superior Court is not binding on the respondent as neither the Attorney General of Canada nor the Minister was involved in the application. … Although the judgment of the Superior Court is not binding on the respondent and is not res judicata, the conduct of the parties, both before and after the concluding of the transaction, clearly demonstrates their true intention to purchase and sell the shares of Quatre Saisons for nominal consideration and not for consideration based on the future sales of lots. ... The financial statements of Quatre Saisons for its fiscal years ending on March 31 of 2003, 2004 and 2005, also reflected the commissions paid in the cost of the sales of the lots. … [I]t is evident that the agreement, as reduced to writing, contained drafting errors of material importance …. ...

From 2002 to 2006, the U.S. s collected approximately US $5.4 billion in duties in relation to imports of Canadian softwood lumber products into the United States. Although a few – including Oroville – were U.S. companies, the vast majority of the importers of record who paid the duties were Canadian lumber producers. ... This can only be so if the application of the SLPECA to the Appellant is justified on the ground of territoriality. … Translated to the case at bar, the question is whether there is a "real and substantial link" between Canada and the activities giving rise Canada's claim for tax. ...

Bocock J stated (at paras 10, 14, 15): … Non est factum is available where a person is not capable of both reading and sufficiently understanding a document. … … The medical evidence … commences from the diagnosis date [of metastatic cancer in 2002]. … With the exception of Mr. ... Therefore, the notices of reassessments responsive to the 2003 filings … were void. … [T]he reassessments were consequential to invalid or unlawful filings and issued by the Minister under innocent mistake of fact. Accordingly, no objection was required to the void reassessments. … Bocock J went on (at para. 24) to issue an order “vacating the operative (re)assessments for the 1998, 2001 and 2002 taxation years, which in turn were responsive to the void 2003 filings”- and to find (at para. 22) that the reassessments for “the 1999 and 2000 taxation years … pre-date the period of probable incapacity (i.e. the diagnosis date) and lack or inability to give authority for filing” and, thus, were valid as they had been received by Anna at her address and the time to grant an extension to object had passed.. ...

. … Regarding the nature of the segregated fund at issue, I conclude that the overarching feature was the life insurance component. ... In paying each appellant the sum of $5,096.08 on February 21, 2002, London Life was fulfilling a legal obligation. The Minister assumed – incorrectly – that the segregated fund belonged in the same category as an RRSP or RRIF. ...

The Queen, 2018 TCC 59-- summary under Consideration Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Consideration statutorily-mandated waste recycling charges were consideration for a taxable supply Stewardship Ontario (“SO”) was a not-for-profit corporation that operated, as part of a regime governed by the Waste Diversion Act, 2002 (Ontario) ('WD Act"), an Ontario program for recycling various types of waste such as paints, solvents, batteries, empty propane tanks and antifreeze. ... Specifically, section 30 and subsections 31(1) and 34(6) of the WD Act provide that if a person has a commercial connection with designated waste or a product from which the designated waste is derived that person (i.e., a steward) must pay a portion of the Appellant’s cost of developing, implementing and operating a waste diversion program …. ... Once a person is found to have, under the MHS Waste Program Agreement, the required commercial connection with the MHS Waste, the person is deemed to be an MHSW Steward. … [O]nce the person becomes an MHSW Steward that person is required to pay the costs of collecting and recycling the designated waste. ...