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TCC

J & L Video Limited v. Her Majesty the Queen (Informal Procedure), [1994] 2 CTC 2114

They read: PURCHASE PRICE BREAKDOWN AGREEMENT ON THE PURCHASE OF J & L VIDEO LTD. ... The subject line is: "Re: Sale of Assets J & L Video to Len Hryciw". ... Even in that context it does not speaK of J & L Video Ltd. acquiring anything. ...
TCC

Oil & Rubber Specialties Inc. v. M.N.R., docket 1999-272-CPP

Oil & Rubber Specialties Inc. v. M.N.R., docket 1999-272-CPP Date: 19990803 Docket: 1999-272-CPP BETWEEN: OIL & RUBBER SPECIALTIES INC., Appellant, and THE MINISTER OF NATIONAL REVENUE, Respondent, and LOUISE RICHARD, Intervenor. ... (iii) ownership of tools what was provided to the Worker to perform his/her work, if anything? ... The test is conclusive all the evidence must be examined and the tests applied in order to determine the totality of the relationship at issue. ...
TCC

Oil & Rubber Specialties Inc. v. M.N.R., docket 1999-38-CPP

Oil & Rubber Specialties Inc. v. M.N.R., docket 1999-38-CPP Date: 19990803 Docket: 1999-38-CPP BETWEEN: OIL & RUBBER SPECIALTIES INC., Appellant, and THE MINISTER OF NATIONAL REVENUE, Respondent, and PAUL E. ... (iii) ownership of tools what was provided to the Worker to perform his/her work, if anything? ... The Worker was held out by the Appellant to be an integral part of Oil & Rubber Specialties Inc. on the Worker's business cards and on the Appellant's organizational charts all of which were entered as exhibits during the trial. ...
TCC

Ergorecherche & Conseils Inc. v. R., [1998] 3 CTC 2062, [1998] DTC 1710

Paragraph 37(1)(a) of the Act refers to an expenditure of a current nature made on SR & ED. Paragraph 37(8)(«) of the Act provides that expenditures on or in respect of SR & ED are expenditures directly attributable to the prosecution of SR & ED. ... However, how can a salary paid on the basis of a business’ liquid assets be connected with SR & ED? ...
TCC

Ferme Jules Côté & Fils Inc. v. Her Majesty the Queen and Jules Côté v. Her Majesty the Queen, [1996] 3 CTC 2361 (Informal Procedure)

Ferme Jules Côté & Fils Inc. v. Her Majesty the Queen and Jules Côté v. ... He said Ferme Jules Côté & Fils Inc. had a turnover of some $1 million and an audited accounting system. ... Proulx found no trace of these purchases in the books of Ferme Jules Côté & Fils Inc. or in Mr. ...
TCC

Milan Hrovat, M & H Doors LTD v. Minister of National Revenue, [1983] CTC 2662, 83 DTC 590

In the instant matter, the applicant, Milan Hrovat, did not appear he apparently could not, due to a medical problem. However, both of the partners of the accounting firm Folkard & Co, a Mr Rupert N Folkard, CA, and Mr Sam Ramessar, CA, did give testimony. ... The Minister’s assertion must be directed, therefore, toward the second issue the involvement of the agents, Folkard & Co. ...
TCC

A. Hansen & Sons Construction Ltd. v. Minister of National Revenue, [1986] 1 CTC 2576, 86 DTC 1425

Hansen & Sons Construction Ltd. (Hansen Construction) with respect to its 1979 taxation year. ... His evidence as to the appellant’s trading history can be summarized as follows: 1. 1976 The appellant purchased the Schnell & Barrie Building. ... The acquisition of the Schnell & Barrie building had been a profitable exercise. ...
TCC

Hi-Rise Electric & Signs Ltd. v. M.N.R., docket 98-159-CPP

Hi-Rise Electric & Signs Ltd. v. M.N.R., docket 98-159-CPP Date: 19990910 Dockets: 98-995-UI; 98-159-CPP BETWEEN: HI-RISE ELECTRIC & SIGNS LTD., Appellant, and THE MINISTER OF NATIONAL REVENUE, Respondent. ... ISSUE: [1] The issue is whether ten employees of the Appellant were, from March 1, 1997 to August 20, 1997 in "insurable employment" as that term is set out in section 5(1) of the Employment Insurance Act (" Act ") and whether they were in pensionable employment within the meaning of the Canada Pension Plan (" CPP "). ...
TCC

Cornella & Jacob Krahn v. The Queen, docket 2000-2487(IT)I (Informal Procedure)

Cornella & Jacob Krahn v. The Queen, docket 2000-2487(IT)I (Informal Procedure) ...
TCC

Browning Harvey Limited and A. Harvey & Company Limited v. Minister of National Revenue, [1988] 1 CTC 2209, 88 DTC 1164

Harvey & Company Limited v. Minister of National Revenue, [1988] 1 CTC 2209, 88 DTC 1164 Goetz, T.C.J. ... Harvey & Company Limited ("Harvey"), appeals with respect to reassessments by the Minister of its 1982 and 1983 taxation years. ... The money was lost and the losses were capital losses to Stewart & Morrison Limited. ...

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