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TCC (summary)

Le Groupe PPP Ltée v. The Queen, 2017 TCC 2, briefly aff'd 2018 FCA 123 -- summary under Illegality

. [I]n civil law, it is quite possible to have an insurance contract without having a qualified or accredited insurer. ...
TCC (summary)

GEM Health Care Group Limited v. The Queen, 2017 TCC 13 -- summary under Subsection 232(3)

This reduction was effected by adjustment to the fee amounts and HST thereon in its books of account, but with no credit notes being issued by it but it nonetheless claimed input tax credits equal to the HST amount on such fee reductions. ...
TCC (summary)

Kion v. The Queen, 2009 TCC 447 -- summary under Section 285

. They reported “zero” income in both taxation years; they provided false information to the Minister to cause the partnership to be deregistered for GST and made no returns. ...
TCC (summary)

Dyck v. The Queen, 2007 TCC 458 -- summary under Subsection 15(1)

Three years later, the same accountant recommended that the taxpayers “restore the status quo ante " (para. 5), which they did by transferring the funds back to the corporation. ...
TCC (summary)

Paradis v. The Queen, 2004 TCC 676 (Informal Procedure) -- summary under Subsection 171(1)

. [A]s there is no valid appeal instituted before this Court under section 169 of the Act, the appellant's relief, if any, is most probably to be had by way of a declaration under subsection 18(1) of the Federal Courts Act. ...
TCC (summary)

Sira Enterprises Ltd. v. The Queen, docket 98-2463-GST-G -- summary under Subsection 191(3)

When one has due regard to the departmental policy on the fair market value approach it is clear that this policy approach says that no method should be discounted. ...
TCC (summary)

Demers v. The Queen, 2014 TCC 368 -- summary under Subsection 146(8)

. Consequently, the nullification pronounced by the Superior Court does not change the fact that the appellants received the amounts…in question and that they were amounts withdrawn from their respective RRSPs. ...
TCC (summary)

McInnes v. The Queen, 2014 TCC 247 (Informal Procedure) -- summary under Subsection 1100(14)

Before so concluding, he stated (para. 36 TaxInterpretations translation): [T]here is income from property rather than income from a business when the appellant cannot demonstrate that the range of services provided by her are such that the payments can in substantial part ["bonne partie"] be attributed to such services. ...
TCC (summary)

Nestlé Canada Inc. v. The Queen, 2017 TCC 33 -- summary under Section 232.1

. Nestlé’s repayments of the IRCs were credited against future Nestlé product purchases by Costco…. ...
TCC (summary)

Rio Tinto Alcan Inc. v. The Queen, 2017 TCC 67 -- summary under Subsection 152(4.01)

She stated (at paras. 258, 261, Tax Interpretations translation): [N]othing in subsection 152(4.01) precludes the Minister from including the amount of tax payable on the previous un-amended assessment in a reassessment made under subsections 152(4) and 152(4.01). ...

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