Search - 2025年四川高考重本线

The Queen, 94 DTC 1009, [1994] 1 CTC 2025 (TCC)-- summary under Subsection 163(3) Summary Under Tax Topics- Income Tax Act- Section 163- Subsection 163(3) In an appeal from a penalty imposed by the Minister pursuant to s. 163(2), the Crown was ordered to proceed with its case first. ...

Royal Bank of Canada v Commissioners for His Majesty's Revenue and Customs, [2023] EWCA Civ 695, aff'd [2025] UKSC 2-- summary under Income Tax Conventions Summary Under Tax Topics- Treaties- Income Tax Conventions French version relevant to interpretation Falk LJ was assisted in arriving at a restrictive interpretation of Art. 6 of the Canada-U.K. ...

The Queen, 94 DTC 1009, [1994] 1 CTC 2025 (TCC)-- summary under Subsection 163(2) Summary Under Tax Topics- Income Tax Act- Section 163- Subsection 163(2) As a result of the negligence of the chartered accountant who was preparing the taxpayer's return, a dividend of $181,211 received by the taxpayer was not reported. ...

The King, 2024 TCC 9, rev'd in part 2025 FCA 60-- summary under Subsection 18.1(2) Summary Under Tax Topics- Other Legislation/Constitution- Federal- Federal Courts Act- Section 18.1- Subsection 18.1(2) collection matters for the Federal Court Owen J indicated in obiter (at para. 161) that the question of whether a payment by a taxpayer should have been applied to his 1988 taxation year was a “collection matter that is outside this Court’s jurisdiction.” ...

The King, 2025 TCC 16-- summary under Subsection 248(26) Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(26) deeming of taxpayer liability to be an obligation Before going on to find that advances made to an employee as a performance award constituted loans and after paraphrasing s. 248(26), Ouimet J stated (at para. 35): Consequently, for a taxpayer who either becomes liable to repay money they borrowed or becomes liable to pay an amount (other than interest) as consideration for any property they acquired, the liability shall be considered to be an “obligation” for the purposes of applying the relevant provisions of the ITA. ...

The King, 2025 TCC 36 (Informal Procedure)-- summary under Paragraph 248(7)(a) Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(7)- Paragraph 248(7)(a) CRA presumption that application was mailed no more than 5 business days before stamped as received by CRA mailroom, was rejected For the purposes of applying ETA s. 334(1) (similar to ITA s. 248(7)(a)), Yuan J refused to accept a CRA administrative presumption that an application could not have been mailed more than 5 business days before its stamping as received by the CRA mailroom, and instead preferred the evidence of the taxpayer’s accountant that she had mailed the application a month previously. ...

The King, 2025 TCC 34-- summary under Paragraph 53(1)(a) Summary Under Tax Topics- Other Legislation/Constitution- Federal- Tax Court of Canada Rules (General Procedure)- Section 53- Subsection 53(1)- Paragraph 53(1)(a) pleadings of assumptions of facts in the alternative were prejudicial to the taxpayer Graham J ordered that the Crown’s pleading, that the purchase by the deceased taxpayer of shares of a company occurred “singly or jointly with” a corporation owned by him, should be struck (with leave to file amended pleadings), as acquisition of beneficial ownership by the taxpayer’s company or by him personally were mutually inconsistent, and substantially affected the case his estate would have to make. ...

Canada, 2025 FCA 6-- summary under Subsection 171(1) Summary Under Tax Topics- Income Tax Act- Section 171- Subsection 171(1) judgments should not be provided to the parties in draft for non-substantive comments The Tax Court judge sent a draft judgment (to disallow the taxpayers’ appeal) to the parties and asked for their comments on any “typographical, grammatical, punctuation, or [any] similar error[s] or any omissions” and any “comments in respect of the written presentation of…[the] decision”, but not so as to revisit the substance of the decision. ...

Canada, 2025 FCA 20-- summary under Subsection 245(4) Summary Under Tax Topics- Income Tax Act- Section 245- Subsection 245(4) Deans Knight applied to corporate restart plan Under a “restart” plan, the appellant changed its name, spun out its existing mining assets so that it was a shell with only tax losses, and B.C. real estate companies of two individuals (Grippo and Heung) transferred various real estate assets, including jointly owned properties, to the appellant for consideration that included shares of the appellant. ...