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Morin v. Agence du revenu du Québec, 2023 QCCQ 2406 -- summary under Income-Producing Purpose

Agence du revenu du Québec, 2023 QCCQ 2406-- summary under Income-Producing Purpose Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Income-Producing Purpose management fees paid to a related company that performed its functions through the agency of the fee payer were non-deductible Prior to 2002, a pharmacist (“Morin”) carried on directly and through her employees all of the operations of six pharmacies. A services agreement concluded in 2002 between her and her management company (“377”) provided that various expenses including some of the payroll expenses were incurred by her as agent for 377. ... Morin had no expectation of receiving any income from the management fees she paid to 377. It seems obvious that a reasonable businesswoman, considering only her commercial interests, would not have committed herself to such an expense. ...