Cases
United States of America v. Harden, 63 DTC 1276, [1963] CTC 450, [1963] S.C.R. 366
The U.S. government obtained a judgment from a U.S. court for U.S. income taxes owing by the respondent, who now was resident in B.C. In affirming...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Statutory Interpretation - Territorial Limits | revenue rule | 48 |
See Also
Ben Nevis (Holdings) Ltd. v. Revenue and Customs Commissioners, [2013] BTC 485, [2013] EWCA Civ 578
Before rejecting the taxpayer's submission that Article 25A did not apply to permit the collection through the respondent (HMRC) of South African...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Statutory Interpretation - Retroactivity/Retrospectivity | creation of new collection right did not entail retrospectivity | 159 |
| Tax Topics - Statutory Interpretation - Revenue Rule | pre-Treaty revenue rule | 122 |
| Tax Topics - Treaties | Vienna convention approach applies to non-signatories | 197 |
| Tax Topics - Treaties - Article 26A | new tax collection Article applied to old tax debts | 222 |
Ben Nevis (Holdings) Ltd. v. Revenue and Customs Commissioners, [2013] BTC 485, [2013] EWCA Civ 578
Before rejecting the taxpayer's submission that Article 25A of the Convention between South Africa and the U.K. did not apply to permit the...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Statutory Interpretation - Retroactivity/Retrospectivity | creation of new collection right did not entail retrospectivity | 159 |
| Tax Topics - Treaties | Vienna convention approach applies to non-signatories | 197 |
| Tax Topics - Statutory Interpretation - Revenue Rule | 116 | |
| Tax Topics - Treaties - Article 26A | new tax collection Article applied to old tax debts | 222 |
Relfo Ltd. v. Varsani (2008), 11 ITLR 783 (Singapore HC)
The day before going into liquidation, the directors of a company transferred all the company's assets to an overseas bank, with the equivalent...