Search - 2005年 抽纸品牌 质量排名
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Decision summary
Kretztechnik AG v Finanzamt Linz, [2005] EUECJ C-465/03, [2006] BVC 66 (ECJ (1st Chamber)) -- summary under Subsection 169(1)
Kretztechnik AG v Finanzamt Linz, [2005] EUECJ C-465/03, [2006] BVC 66 (ECJ (1st Chamber))-- summary under Subsection 169(1) Summary Under Tax Topics- Excise Tax Act- Section 169- Subsection 169(1) costs of raising share capital were traceable to taxable outputs Kretztechnik raised capital through a share issue. ... Thus, the right to deduct VAT charged on the acquisition of input goods or services presupposes that the expenditure incurred in acquiring them was a component of the cost of the output transactions that gave rise to the right to deduct … [36] In this case, in view of the fact that, first, a share issue is an operation not falling within the scope of the [Directive] and, second, that operation was carried out by Kretztechnik in order to increase its capital for the benefit of its economic activity in general, it must be considered that the costs of the supplies acquired by that company in connection with the operation concerned form part of its overheads and are therefore, as such, component parts of the price of its products. ...
TCC
Gilbert v. The Queen, 2005 TCC 672
The Queen, 2005 TCC 672 Docket: 2002‑3402(IT)G BETWEEN: PIERRE GILBERT, Appellant, and HER MAJESTY THE QUEEN, Respondent. ... Signed at Ottawa, Canada, this 17th day of October 2005. "Louise Lamarre Proulx" Lamarre Proulx J. ...
TCC
IncoLimited v. The Queen, 2004 TCC 373, aff'd 2005 DTC 5110, 2005 FCA 44
The Queen, 2004 TCC 373, aff'd 2005 DTC 5110, 2005 FCA 44 Docket: 2002-2695(IT)G BETWEEN: INCO LIMITED, Appellant, and HER MAJESTY THE QUEEN, Respondent. ____________________________________________________________________ Determination of a question pursuant to Rule 58 of the Tax Court of Canada Rules (General Procedure), heard on September 25, 2003, at Toronto, Ontario, By: The Honourable Justice A.A. ... Costs will be at the discretion of the trial judge. Signed at Ottawa, Canada, this 31st day of May, 2004. ... Sarchuk" Sarchuk J. Citation: 2004TCC373 Date: 20040531 Docket: 2002-2695(IT)G BETWEEN: INCO LIMITED, Appellant, and HER MAJESTY THE QUEEN, Respondent. ...
TCC
Chagnon v. M.N.R., 2005 TCC 46
., 2005 TCC 46 Docket: 2003-4675(EI) BETWEEN: ROBERT CHAGNON o/a MIRODI ENR., Appellant, and THE MINISTER OF NATIONAL REVENUE, Respondent, and MICHEL PERREAULT, Intervener. ... Savoie" Deputy Judge Savoie Translation certified true on this 6th day of April 2005. ... Savoie" Deputy Judge Savoie Translation certified true on this 6th day of April 2005. ...
Public Transaction Summary
Sirius XM -- summary under Exchangeable Share Acquisitions
Sirius XM-- summary under Exchangeable Share Acquisitions Summary Under Tax Topics- Public Transactions- Mergers & Acquisitions- Cross-Border Acquisitions- Inbound- Exchangeable Share Acquisitions exchangeable shares offered by Canadian-controlled purchaser (minority-owned by Sirius XM (Del.) sub) Overview A Delaware subsidiary (the “Guarantor”) of SIRI holds approximately a 37% equity interest in the “Company (some of it in the form of non-voting shares to address CRTC non-resident control issues) and two Canadian corporations (Slaight and Obelysk), together have approximately a 22.4% equity interest in the Company. ... On April 25, 2016, the Company received a demand letter from the Guarantor for an additional US$33.9 million as "activation fees" under one of the licences owed from 2005 to the end of January, 2016. ... Company ownership Principal Shareholder Type of Ownership Number of class A Shares assuming conversion of Class B and Class C Shares Percentage of Class A Shares Outstanding assuming conversion of Class B and Class C Shares Voting Interest represented by # of Voting Shares Percentage of Votes Obelysk Direct 12,982,135 10.09% 23,154,901 17.08% Guarantor Direct 47,324,180 36.77% 33,685,653 24.85% CBC Direct 13,056,787 10.15% 13,056,787 9.63% Slaight Direct 15,856,787 12.32% 26,170,361 19.31% Obelysk holds its interest in the form of 15,259,149 Class B Shares and 7,887,307 Class A Shares. ...
Technical Interpretation - External summary
17 March 2005 External T.I. 2005-0118601E5 F - Sale of Shares-Transfer of Family Business -- summary under Subparagraph 84.1(2)(a.1)(ii)
17 March 2005 External T.I. 2005-0118601E5 F- Sale of Shares-Transfer of Family Business-- summary under Subparagraph 84.1(2)(a.1)(ii) Summary Under Tax Topics- Income Tax Act- Section 84.1- Subsection 84.1(2)- Paragraph 84.1(2)(a.1)- Subparagraph 84.1(2)(a.1)(ii) preliminary s. 85(1)(g) exchange transaction for crystallized preferred shares avoided application of s. 84.1(2)(a.1)(ii) An individual ("A") wholly-owning Holdco, held Holdco common shares with a nominal FMV, ACB and PUC, and Holdco preferred shares having an FMV of $1M and an ACB of $0.5 million (as a result of a previous capital gains crystallization transaction) and a nominal PUC. ... CRA indicated that on the disposition by the children to Newco for $0.5M of their common shares of Holdco acquired for $0.5M, the aggregate ACB to them of such shares would not have been reduced pursuant to s. 84.1(2)(a.1)(ii) (before any GAAR application), stating: [N]o part of the aggregate ACB to the children of the common shares of the capital stock of Holdco would be attributable to the capital gains deduction claimed by A … on the crystallization transactions … [given] that, by the application of paragraph 85(1)(g), the entire amount of the capital gain realized by A and in respect of which he would have claimed a capital gains deduction pursuant to section 110.6 would have been attributed to the preferred shares of the capital stock of Holdco. ...
TCC
Agneau de L'Est Inc. v. M.N.R., 2005 TCC 401
Signed at Ottawa, Canada, this 28th day of July 2005. "Alain Tardif" Tardif J. ... Signed at Ottawa, Canada, this 28th day of July 2005. "Alain Tardif" Tardif J. ... Signed at Ottawa, Canada, this 28th day of July 2005. "Alain Tardif" Tardif J. ...
FCTD
Ellingson v. Canada (Minister of National Revenue), 2005 DTC 5492, 2005 FC 1068
Canada (Minister of National Revenue), 2005 DTC 5492, 2005 FC 1068 Date: 20050804 Docket: T-1476-04 Citation: 2005 FC 1068 Vancouver, British Columbia, Thursday the 4 th day of August, 2005 Present: THE HONOURABLE MR. ... Campbell" Judge FEDERAL COURT NAMES OF COUNSEL AND SOLICITORS OF RECORD DOCKET: T-1476-04 STYLE OF CAUSE: ROGER ELLINGSON- and- THE MINISTER OF NATIONAL REVENUE PLACE OF HEARING: Vancouver, BC DATE OF HEARING: August 2, 2005 REASONS FOR ORDER AND ORDER: CAMPBELL J. DATED: August 4, 2005 APPEARANCES: Mr. ...
Technical Interpretation - External summary
22 March 2005 External T.I. 2004-0098591E5 F - Application de l'alinéa 212(9)d) proposé -- summary under Paragraph 212(9)(d)
22 March 2005 External T.I. 2004-0098591E5 F- Application de l'alinéa 212(9)d) proposé-- summary under Paragraph 212(9)(d) Summary Under Tax Topics- Income Tax Act- Section 212- Subsection 212(9)- Paragraph 212(9)(d) extension to provincial regulatory authority under review CRA indicated that the exemption as then worded did not apply if a provincial rather than federal authority was the party to the reinsurance indenture – but this matter was under consideration by Finance. ...
Technical Interpretation - External summary
6 January 2005 External T.I. 2004-0088791E5 F - Paragraphe 4803(2) du Règlement -- summary under Subsection 4803(2)
6 January 2005 External T.I. 2004-0088791E5 F- Paragraphe 4803(2) du Règlement-- summary under Subsection 4803(2) Summary Under Tax Topics- Income Tax Regulations- Regulation 4803- Subsection 4803(2) Reg. 4803(2) satisfied if any of its paragraphs is satisfied CRA indicated, based on the meaning of “or”: [T]he conditions listed in paragraphs 4803(2)(a) to (d) … are not cumulative. ...