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...
Restricted gold import conditions: breach permits absolute confiscation, while redemption remains discretionary and is rarely disturbed on writ review...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4886 
