Search - 2002年 抽纸品牌 质量排名
Results 121 - 130 of 11066 for 2002年 抽纸品牌 质量排名
TCC (summary)
Bourgault v. The Queen, 2019 TCC 6 -- summary under Rectification & Rescission
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 …. ...
TCC (summary)
Oroville Reman & Reload Inc. v. Canada, 2016 TCC 75 -- summary under Territorial Limits
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. ...
Decision summary
Birch Hill Equity Partners Management Inc. v Rogers Communications Inc., 2015 ONSC 7189 -- summary under Rectification & Rescission
., 2015 ONSC 7189-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission stock option deduction was peripheral to the larger share sale transaction The general partner of an Ontario limited partnership (“Atria”) granted stock options on its Class C shares to 10 Atria executives. ... Respecting the second point, he stated (at para. 42) before quoting Performance Industries, 2002 SCC 19, at para. 31 that “rectification in cases of unilateral mistake is possible, but the requirements for invoking this doctrine are intentionally much, much narrower and thus more demanding.” ...
Technical Interpretation - Internal summary
8 October 2004 Internal T.I. 2004-0093371I7 F - Crédit d'impôt à l'investissement & impôt minimum -- summary under Subparagraph 127(5)(a)(ii)
8 October 2004 Internal T.I. 2004-0093371I7 F- Crédit d'impôt à l'investissement & impôt minimum-- summary under Subparagraph 127(5)(a)(ii) Summary Under Tax Topics- Income Tax Act- Section 127- Subsection 127(5)- Paragraph 127(5)(a)- Subparagraph 127(5)(a)(ii) carryback of ITCs from year where the taxpayer was subject to minimum tax After noting that where minimum tax applies in a particular taxation year (here, 2003), the deductible amount of investment tax credit in respect of property acquired in that year is limited under s. 127(5)(b) to the amount by which the tax otherwise payable under Part I for the year (2003) exceeds the minimum tax applicable to the individual for that year, the Directorate went on to note that the unused investment tax credit balance be carried back to previous years (2000 to 2002) if the investment tax credit amount is higher than this excess: for purposes of the carryback to such prior years, s. 127(5)(a)(ii) takes into account the balance that was not deductible in the particular taxation year (2003). ...
Technical Interpretation - Internal summary
16 November 2015 Internal T.I. 2015-0598491I7 - 91(5) & FAPI included per “old” 94(1)(c)(i)(C) -- summary under Subsection 91(5)
16 November 2015 Internal T.I. 2015-0598491I7- 91(5) & FAPI included per “old” 94(1)(c)(i)(C)-- summary under Subsection 91(5) Summary Under Tax Topics- Income Tax Act- Section 91- Subsection 91(5) upward ACB adjustment to the CFA occurring as a result of recognized FAPI under the old s. 94(1) rules represented basis that could be distributed while the trust was subject to the new s. 94(3) trust rules A non-resident discretionary trust (“NRT”) owned all the shares of CFA. Amounts in respect of CFA’s foreign accrual property income had to be included in NRT’s 2002, 2004 and 2006 taxable income by virtue of “old” s. 94(1)(c)(i)(C) (“FAPI-Inclusions”). ...
Technical Interpretation - Internal
21 April 2015 Internal T.I. 2014-0560811I7 - FACL carryback Surplus & PAS election
21 April 2015 Internal T.I. 2014-0560811I7- FACL carryback Surplus & PAS election CRA Tags ITR 5901(2.2) S.79 of Bill C-48 ITR 5901(2.1) ITR 5901(2)(b) 95(1) foreign accrual property income Principal Issues: 1) Do the surplus pools of a given CFA have to be adjusted as a result of a FACL carryback against the TCG portion of the FAPI inclusion reported in a previous year? ... The relevant part of paragraph 79(2)(a) of Bill C-48 reads as follows, as modified to incorporate the relevant deadlines that would be applicable in the context of the facts submitted (see text underlined): (
) if the corporation (
) elect in writing under this paragraph in respect of all of their respective foreign affiliates and file the election with the Minister of National Revenue on or before the day that is the later of (
) the filing-due dates for their taxation years that include the day on which this Act receives royal assent [June 30, 2014] and the day that is one year after the day on which this Act receives royal assent [June 26, 2014], subsections 5901(2) to (2.2) of the Regulations, as enacted by subsection (1), apply to dividends paid after December 20, 2002 by all the respective foreign affiliates of the elector corporations (
) In the context of the present case, the election for the PAS election rules to apply to the 2010-Dividend would have to have been made on or before June 30, 2014. ... Furthermore, the election to make the PAS election rules applicable to dividends paid after December 20, 2002 does not alleviate the taxpayer's responsibility to file the PAS election itself. ...
Technical Interpretation - External
15 December 2006 External T.I. 2006-0182471E5 F - Intérêts " explicitement identifiés "
15 December 2006 External T.I. 2006-0182471E5 F- Intérêts " explicitement identifiés " Unedited CRA Tags 12(1)c) Principales Questions: Demande de précision concernant la position administrative de l'Agence du revenu du Canada énoncée dans les Nouvelles techniques no 30 où cette dernière utilise l'expression " intérêts explicitement identifiés ". ... Nos commentaires Tel qu'il est mentionné au paragraphe 22 de la Circulaire d'information 70-6R5 du 17 mai 2002, notre Direction a comme pratique de ne pas émettre d'opinion écrite concernant des transactions projetées autrement que par voie de décisions anticipées. ...