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TCC (summary)
Choptiany v. The King, 2022 TCC 112 -- summary under Subsection 95(1)
. … The Respondent’s egregious history of defaults and non-compliance in these appeals, that there is no alternative available that could reasonably be expected to cause the Respondent to now comply, and that this has caused prejudice to the Appellants, are reason enough to allow these appeals. ...
TCC (summary)
Gestion M.-A. Roy Inc. v. The King, 2022 TCC 144, aff'd 2024 CAF 16 -- summary under Subsection 246(1)
Smith J confirmed CRA’s inclusions in Gestion Roy’s income under s. 15(1) of the annual premium amounts paid on Gestion Roy’s policies given that it was the owner of such policies (entitling it to the cash surrender value of the policies at any time), so that it was “enriched” when the premiums were paid by R3D – and indicated that it was irrelevant to this point that, in fact, Gestion Roy never received any distribution on its policies. ...
TCC (summary)
Axelrod v. The King, 2022 TCC 157 (Informal Procedure) -- summary under Supply
. … It is even more evident that all aspects of Dr. Axelrod’s reconstruction, in a patient’s mouth, of a significant portion of a tooth, using appropriate filling or restorative materials, were integral components of a composite supply. ...
TCC (summary)
3792391 Canada Inc. v. The King, 2023 TCC 37 (Informal Procedure) -- summary under Subsection 227(8)
I therefore find that the Minister was justified in assessing the penalty pursuant to section 227(8) …. ...
TCC (summary)
Garg Investments Inc. v. The King, 2023 TCC 67 (Informal Procedure) -- summary under Paragraph 256.2(3)(a)
. … Similar to the Cheema decision, it is the relationship between the purchaser and the seller that is relevant to the entitlement to the NRRPR rebate, not the relationship between the co-purchasers. ...
TCC (summary)
Nicoll v. The King, 2023 TCC 116 (Informal Procedure) -- summary under Subparagraph 6(1)(b)(vii)
Here, regarding s. 6(1)(b)(vii) “its wording requires that the employee be travelling away from the employer’s establishment … [whereas h]ere, Burnaby City Hall has no connection to the employer’s establishment so the allowance received by Mr. ...
TCC (summary)
FOOi Inc. v. The King, 2023 TCC 176 -- summary under Subsection 166.1(2)
. … The Applicant never sent a Notice of Objection for the 2018 taxation year in a timely fashion. ...
TCC (summary)
Sussex Group - Allan Sutton Realty Corp. v. The King, 2024 TCC 1 (Informal Procedure) -- summary under Subsection 227(9)
. …. And adjusting the quantum of a given penalty would be beyond the jurisdiction of this Court. ...
TCC (summary)
Windsor Clinical Research Inc. v. The King, 2023 TCC 179 -- summary under Section 54
… [N]either party is bound by their approach prior to the court appeal. ...
TCC (summary)
Lark Investments Inc. v. The King, 2024 TCC 30 -- summary under Subsection 245(4)
St-Hilaire J found (at para. 60) that the relevant part of the Reply “may prejudice the fair hearing of the appeal and is an abuse of process” and should be struck – but with leave to the Crown to amend its pleadings. ...