Charitable sports promotion: sponsorship receipts alone did not defeat registration where funds supported tournaments and player development activitie...
Overdue associated-enterprise receivables: debt-free status defeated notional-interest adjustment, while employee stock-option costs qualified as busi...
Retrospective assessment-limitation amendments validate final orders while contemporaneous segment data governs transfer-pricing comparability and tol...
Transfer pricing adjustments must track international transactions, while unsupported AMP adjustments and unsuitable manufacturing comparables require...
Transfer-pricing adjustments must reflect functional comparability, working-capital effects, and avoid duplicating interest on associated-enterprise r...
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Provisional attachment of alleged proceeds of crime represented as long-term capital gains from share sales continued because the share purchasers appeared to have been funded from sources other than their own. Funds were routed through banking channels to acquire shares in non-functioning companies at highly appreciated prices, without an apparent commercial basis for the valuation. The investment explanation was treated as unconvincing, including in light of the appellant's role in the trust operating the university. As the scheduled-offence and money-laundering trials remained pending, the attachment was retained to secure the alleged proceeds of crime until trial conclusion.
Provisional attachment of alleged proceeds of crime represented as long-term capital gains from share sales continued because the share purchasers appeared to have been funded from sources other than their own. Funds were routed through banking channels to acquire shares in non-functioning companies at highly appreciated prices, without an apparent commercial basis for the valuation. The investment explanation was treated as unconvincing, including in light of the appellant's role in the trust operating the university. As the scheduled-offence and money-laundering trials remained pending, the attachment was retained to secure the alleged proceeds of crime until trial conclusion.
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