Search - ”资源化利用" resources

Results 1861 - 1870 of 1913 for ”资源化利用" resources
TCC

Donald Thomson, Anne Taylor and John W. White v. Minister of National Revenue, [1994] 2 CTC 2136, 93 DTC 320

Triangle Ventures Ltd., (Triangle) had leased certain lands and a company called Nuspar Resources Ltd. ... Then, in the same letter, Sawyer went on to say: TTW does not now, and has not at any time had any relationship with Triangle Ventures Ltd., Nuspar Resources Ltd., the Sombrio Point placer property, Dr. ... The transaction between TTW and SAT, a corporation totally owned by White, on October 10, 1984 the last day of the “quick flips” is illustrative of the outrageous conflict of interest played out in the sorry saga of TTW's history. ...
TCC

Duha Printers (Western) Limited v. Her Majesty the Queen, [1995] 1 CTC 2481, 95 DTC 828

At all material times, the voting shares of Emdulis Ltd. were held as follows: Shareholder*Class & No. of Shares Gwendolyn Duha500 common Emeric J. ... Hutchinson J. of the Alberta Court of Queen’s Bench considered the Imperial General Properties case in Harvard International Resources Ltd. v. ... In Harvard International Resources, de jure control of the taxpayer rested with one shareholder’s ownership of 150 preferred shares. ...
TCC

Florianne Cardinal, Michel Beaudry, Beaudry Construction (Quebec) Ltée and Jeannine d'AMOUR v. Minister of National Revenue, [1992] 1 CTC 2437

However, because of his sisters who had reached a certain age and who did not have the same financial resources as he, he agreed to the others' wish to sell. ... Moreover, he listed the reasons why he considered the profit to be income from a business: One of the co-owners reported the sale of the lot as income from a business. No documentary or other evidence has been provided to us to date to indicate that a shopping centre would be built on your lot at the time of acquisition. Some of the co-owners are involved in the real estate market. ... These involve purchases and sales of lots in Gatineau and Templeton. In 1975, he has 25 per cent of the shares of Licousi Inc. ...
TCC

Voukelatos v. MNR, 92 DTC 1076, [1992] 1 CTC 2154 (TCC)

According to the evidence, these amounts, totalling $45,000, were from Voukelatos' personal resources. ... Ross & Son Ltd. (1982), 40 N.B.R. (2d) 563 (N.B.Q.B.); Bank of Montreal v. ... & P.E.I.R. 179 (Nfld. C.A.); Ghadban v. Bank of Nova Scotia (1982), 132 D.L.R. (3d) 475 (Ont. ...
TCC

Parton v. R.|, 99 DTC 738, [1999] 2 CTC 2755 (TCC)

The Appellant and other persons (-) reported to the Advisors, who in turn determined the course of action of 605892. 5. ... From approximately April 1993 onwards, (-) the Appellant derived no remuneration from 605892 or Shannon. ... Here are some of his words: …] can assure you that we are operating the company through a very difficult start-up period to enhance the value for all stakeholders. ...
TCC

Georgetown Investments Limited v. Minister of National Revenue, [1990] 2 CTC 2232, 90 DTC 1728

Suffice it to say that one Luis Bankovsky was the lessee of certain placer claims owned by Kluane Resources Ltd. ... Plummer: Okay, now we're talking about when Kluane Gold Mr. Paris: Exercised A.: —on paper, on paper signed a contract to acquire and purchase for $800,000 the total assets and the property that was involved in the mining situation. ... By the time we had a chance to pursue that, he rolled down most of his assets Q.: We being? ...
TCC

Société d’Investissement Desjardins v. Minister of National Revenue, 91 DTC 393, [1991] 1 CTC 2214 (TCC)

The remaining 25 per cent came from interest on these investments and interest earned on loans made between 1974 and 1976. 3.0 7 In order to perform its role as an active partner, SID concentrated its resources by investing in a limited number of businesses. ... Concerning the meaning of the expression ordinary course of the business carried on” by the specified financial institution, Mr. ... Dyer states ‘the following at page 25 of an article published in Corporation Tax Conference—1986" (Tab B below):... ...
TCC

Allen v. The Queen, docket 97-3243-IT-I (Informal Procedure)

He said that the loss did occur and that it was an allowable business investment loss within the meaning of the Income Tax Act, R.S.C. 1985, c. 1 (5 th Supp.) as amended (the " Act "). ... This was divided 50 50 between the Allens because both were shareholders and the money came from both of them. ... There was $306,094.00 claimable as an ABIL which was split 50 50 between the Appellants. ...
TCC

Larsen v. The Queen, docket 97-2648-IT-G

The plaintiff's husband, who had limited financial resources, could not accept his wife being the owner of a holiday cottage on which he himself could not pay the expenses. ... Investments Inc. a profit à prendre when they granted it "... a right to remove timber from the properties" (Exhibit AR-1, Tab 4, page 1). ...
TCC

Thunder Bay Symphony Orchestra Assn. Inc. v. M.N.R., docket 97-1348-UI

The objectives of the Association are best met through a co-operative undertaking to provide a community-based musical resource for the region, providing employment for both professional and community players residing in the regions. 2. ... ". There is no doubt in my mind that the Master Agreement not only looks like a collective agreement but is in fact a collective agreement. [18] Having decided as an issue of fact that the Master Agreement is a collective agreement because all significant terms of engagement of each core musician are governed by the Master Agreement, I could conclude that each core musician is an employee of the Appellant and not an independent contractor. ...

Pages