Search - 2005年 抽纸品牌 质量排名

. … Because each taxpayer is assessed (or reassessed) separately, this can result in inconsistent assessments (Peterson v. The Queen, 2005 FCA 263 …at paragraph 4). If the Minister has issued inconsistent assessments, this will lead to inconsistent pleadings, if the taxpayers appeal to the Tax Court of Canada. ...

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. ... In finding that the oversight expenses paid to the investment dealers would also have been deductible under s. 20(1)(bb), he rejected the Crown’s submissions that such fees were “commissions” and that they were not in respect of a “specific security” because they were in respect of all the Pechiny or Novartis shares, stating (at paras 89-90, and 96-97): … In my view, neither “specific shares” nor “certaines actions” excludes the possibility that the provision applies to a sale of all of the shares of a particular issuer. ... She has not done so. … He also rejected the Crown's submission that s. 40(1)(a) should prevail over s. 20(1)(bb) as the more specific provision, stating (at para. 97) that "paragraph 40(1)(a) is no more specific than paragraph 20(1)(bb). ...

In 2007, the CRA sent the taxpayer a letter explaining that he might have over-contributed to his RRSPs from 2003 to 2005, thereby giving rise to an obligation to file over-contribution (T1-OVP) returns and pay penalty tax- but that if he withdrew the excess contributions within the statutorily prescribed timeframe, this could be done without withholding tax by filing a T3012A form. ... However, in going on to dismiss his appeal, she stated (at paras, 77-78): … Mr. ... Connolly does not appear to have made any inquiries … to confirm his contribution room. ...

. … Because each taxpayer is assessed (or reassessed) separately, this can result in inconsistent assessments (Peterson v. The Queen, 2005 FCA 263 …at paragraph 4). If the Minister has issued inconsistent assessments, this will lead to inconsistent pleadings, if the taxpayers appeal to the Tax Court of Canada. ...