Search - 2005年 抽纸品牌 质量排名

Following a 2005 audit, CRA offered to settle the issues arising from the 2001 and 2002 taxation years if the taxpayer signed a waiver of his appeal rights for both years respecting his business income and expenses. ... In finding that CRA’s decision should stand, and in rejecting a submission (at para. 23) that “it was unfair for the Minister’s delegate not to ‘match’ the expenses he incurred in paying the rental payments for the two machines against the income he earned by using the machines, and…although his corporation’s name was on the lease with CIT, the corporation was in fact inactive,” Bowell J stated (at paras. 24 to 26): [T]he matching principle is not a rule of law which dictates or requires that expenses must always be matched with profits; it is simply an accounting principle that a court may or may not consider depending upon the particular facts and circumstances of a case. … …The Applicant chose to collect revenue generated by the machines personally, rather than through his corporation, and he cannot rely upon an accounting principle to ignore the legal reality of the lease and argue that the cost of the lease payments should be attributed to him personally and deductible from his personal income for the 2001 taxation year. …... ...

Agence du revenu du Québec, 2025 QCCQ 1127-- summary under Subsection 45(1) Summary Under Tax Topics- Income Tax Act- Section 45- Subsection 45(1) the conversion of apartment buildings to condo units did not trigger a change of use – and that CAE rather than IT-218R would apply re change of use In 1981, the taxpayers (10 individuals), acquired as co-owners two adjoining rental buildings containing a total of 82 apartments, with their respective undivided interests in such properties ranging from 2.27% to 29.2%. ... Revenue Quebec applied the position in IT-218R on change of use and treated such gains as consisting of a capital gain, computed on the basis of a notional disposition of the properties for their FMV at the time of their change of use from capital property to inventory (in 2005, when the decision to convert was taken) and, as to the balance (representing post-2005 appreciation), as business income from the disposition of inventory. ...

In 2005, the taxpayer had licensed his patent respecting fuel line systems (the “Patent”) to an arm’s length company (“Davis Aircraft Inc.”). ... A New York LLC (“Wolfbend”) was established for the purpose of collecting profits earned under the Manufacturing & License Agreement between the taxpayer and Davis Aircraft Inc. and allocating those profits to its members, being the taxpayer, his brother and Davis family members. ... Therefore … the revenues from all three sources qualify as “active business” revenues. ...

In 2004, the taxpayer determined to effect a butterfly spin-off of a portion of its (laminated products) assets, which resulted in the receipt by its shareholders of shares of a new public company (“Novelis”) in January 2005. ... Similarly, respecting the divestiture-related fees of Lazard Frères incurred up to board approval of a butterfly spin-off, these related to advice and approaches to potential third-party purchasers of the shares through which the laminated products business was held as well as to the ultimate sale (on a rollover basis) of the shares of that laminated products company to Novelis in consideration for the acquisition of (subsequently redeemed) preferred shares of Novelis, and the calculation of the Lazard Frères success fee did not represent a percentage of the value of those shares – so that those fees also were deductible under s. 20(1)(bb) as well as under s. 9. ...

The Minister reassessed Burlington’s 2002 to 2005 taxation years to deny under ss. 247(2)(a) and (c) deductions for annual payments made by Burlington to BRI for its unconditional guarantee of the Notes under ss. 247(2)(a) and (c). ... Before granting the amendments, D’Auray J indicated that Rule 132 applied only to “formal admissions” such as in pleadings Andersen Consulting ([1998] 1 FC 605 (FCA)) had established “that an application for leave to withdraw admissions did not require a separate form” (para. 75), so that the requested amendment to the Reply could constitute application to withdraw an admission In Burlington’s examination for discovery of the Crown’s nominee in 2014, “[n]umerous times the respondent’s counsel stated that it was the respondent’s position that no amounts were payable as guarantee fees” (para. 77) Although in an Amended Reply, the Crown had admitted that guarantee fees had been paid in the amounts stated in the Notice of Appeal, “the respondent did not make a clear and deliberate concession that the amounts paid to BRI were guarantees fees” (para. 80) in light of the point immediately above and denials made by the Crown elsewhere in the Reply Even if there had been such an admission, D’Auray J “would still have permitted the withdrawal of the admission since … there is a triable issue which ought to be tried in the interests of justice” (para. 82) “In addition, the purported withdrawal does not amount to an injustice to Burlington since it has been aware of the respondent’s position at least since its discovery of the respondent’s nominee in 2014.” ...