Search - 2002年 抽纸品牌 质量排名

Lavallee, Rackel & Heintz v. Canada (Attorney General); White, Ottenheimer & Baker v. ... Fink, 2002 DTC 7267, 2002 SCC 61, [2002] 3 SCR 209-- summary under Section 8 Summary Under Tax Topics- Other Legislation/Constitution- Charter (Constitution Act, 1982)- Section 8 unconstitutional lack of privilege safeguards In addition to other defects that potentially could be cured by a modest judicial redrafting of the provision, section 488.1 of the Criminal Code was fundamentally flawed in that it failed to ensure that clients were given a reasonable opportunity to exercise their constitutional prerogative to assert or waive their privilege but, instead, established a procedure whereby the privilege could be lost if the lawyers whose law offices were being searched did not advance claims of solicitor-client privilege on a timely basis. ...

Lavallee, Rackel & Heintz v. Canada (Attorney General); White, Ottenheimer & Baker v. ... Fink, 2002 DTC 7267, 2002 SCC 61, [2002] 3 SCR 209-- summary under Subsection 232(3) Summary Under Tax Topics- Income Tax Act- Section 232- Subsection 232(3) unconstitutional lack of privilege safeguards In addition to other defects that potentially could be cured by a modest judicial redrafting of the provision, section 488.1 of the Criminal Code was fundamentally flawed in that it failed to ensure that clients were given a reasonable opportunity to exercise their constitutional prerogative to assert or waive their privilege but, instead, established a procedure whereby the privilege could be lost if the lawyers whose law offices were being searched did not advance claims of solicitor-client privilege on a timely basis. ...

Sylvan Lake Golf & Tennis Club Ltd., 2002 SCC 19, [2002] 1 SCR 678-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission rectification available notwithstanding lack of due diligence on part of plaintiff The plaintiff (“Sylvan”) and the defendant (“Performance”) entered into an agreement respecting a golf course that gave Sylvan the option on the 18 th fairway for a specific residential development to be undertaken by it. ... The plaintiff must establish that the terms agreed to orally were not written down properly. … What is essential is that at the time of execution of the written document the defendant knew or ought to have known of the error and the plaintiff did not. ...

Customs & Excise Commissioners v. Plantiflor Ltd., [2002] UKHL 33, [2002] 1 WLR 2287, [2002] STC 1132', [2002] BTC 5413 (HL)-- summary under Supply Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Supply The taxpayer, which sold horticultural products by mail order, indicated in its catalogue that customers would pay an additional charge to cover the costs of postage and packing, and stated "we will then advance all postage charges to Royal Mail on your behalf. ...

Customs & Excise Commissioners v. Plantiflor Ltd., [2002] UKHL 33, [2002] 1 WLR 2287, [2002] STC 1132', [2002] BTC 5413 (HL)-- summary under Subsection 165(1) Summary Under Tax Topics- Excise Tax Act- Section 165- Subsection 165(1) The taxpayer, which sold horticultural products by mail order, indicated in its catalogue that customers would pay an additional charge to cover the costs of postage and packing, and stated "We will then advance all postage charges to Royal Mail on your behalf. ...

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". ...

The Trustees of the Morrison 2002 Maintenance Trust & Ors v Revenue and Customs, [2019] EWCA Civ 93-- summary under Tax Avoidance Summary Under Tax Topics- General Concepts- Tax Avoidance Three “Scottish Trusts” exercised their put to sell shares of a listed public company to trusts (the “Irish Trusts”) with similar terms for the shares’ cost base of £4.5M; and the Irish Trusts sold the same shares eight days later to Merrill Lynch for £14.3M, who then sold the shares into the market. ... Newey LJ stated (at paras. 56-57) that he agreed with the First-tier Tribunal: that the sale to Merrill Lynch "sufficiently corresponded to the scheme as planned" and … it "would be extraordinary if the application of the Ramsay approach could be defeated by the sale being to brokers rather than to the market by brokers on behalf of the Irish Trustees" …. ...

The Trustees of the Morrison 2002 Maintenance Trust & Ors v Revenue and Customs, [2019] EWCA Civ 93-- summary under Subsection 248(10) Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(10) identifying the form of ultimate sale was not essential to finding a pre-ordained series A scheme for the avoidance by three trusts (the “Scottish Trusts”) of capital gains tax on the sale of a bloc representing approximately 2% of the shares of a listed company (”AWG”) turned on considering that the exercise by the Scottish Trusts of a put to sell the AWG shares for their base cost of £4.5M to trusts (the “Irish Trusts”) with similar terms did not occur (under the Ramsay approach) as part of a single composite transaction which included their sale eight days later to Merrill Lynch for their market value of £14.3M, who then sold the shares into the market. ... Dawson (quoted at para. 27): First, there must be a pre-ordained series of transactions; or, if one likes, one single composite transaction. …. ... The UT held that the FTT had been entitled to conclude that the involvement of Merrill Lynch made no material difference …. ...