Search - 2002年 抽纸品牌 质量排名

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. ...

., 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. ...

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. ...

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. ...

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. ...