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FCA
Dow & Duggan Log Homes International (1993) Limited v. Canada, 2021 FCA 66
HER MAJESTY THE QUEEN PLACE OF HEARING: Heard by online video conference hosted by the Registry DATE OF HEARING: March 24, 2021 REASONS FOR JUDGMENT BY: STRATAS J.A. ... RIVOALEN J.A. DATED: March 31, 2021 APPEARANCES: Melanie Petrunia For The Appellant Stan McDonald For The Respondent SOLICITORS OF RECORD: Nijhawan McMillan Petrunia Halifax, Nova Scotia For The Appellant Nathalie G. Drouin Deputy Attorney General of Canada For The Respondent ...
FCA
Lanno v. Canada (Customes & Revenue Agency), 2005 FCA 153
Canada (Customes & Revenue Agency), 2005 FCA 153 Date: 20050502 Docket: A-478-04 Citation: 2005 FCA 153 CORAM: ROTHSTEIN J.A. ... "I agree. Marshall Rothstein J.A." "I agree. ... " FEDERAL COURT OF APPEAL NAMES OF COUNSEL AND SOLICITORS OF RECORD DOCKET: A-478-04 APPEAL FROM THE ORDER OF MADAM JUSTICE SNIDER DATED JUNE 28, 2004 IN DOCHET T-2282-03 STYLE OF CAUSE: DENIS LANNO and CANADA CUSTOMS AND REVENUE AGENCY PLACE OF HEARING: Toronto, Ontario DATE OF HEARING: April 27, 2005 REASONS FOR JUDGMENT BY: SHARLOW J.A. ...
FCA
Addison & Leyen Ltd. v. Canada, 2006 DTC 6248, 2006 FCA 107
Facts 6 (1) The state of affairs in October of 1988 7- 10 (2) Payments made by York between October of 1988 and October of 1989 11- 13 (3) The sale of York to Senergy 14- 19 (4) Payments made by Addison in 1989 20- 21 (5) Communications with tax officials in 1990, 1991 and 1992 22 (6) The reassessment of York in 1992 23- 24 (7) Events in 1989 and 1999 25- 28 (8) The section 160 assessments 29- 35 C. ... 49- 51 (i) The elements of section 160 52- 54 (ii) The history of section 160 55- 56 (iii) Section 160 and dividends 57- 60 (iv) The application of section 160 to other corporate payments 61- 62 (v) Section 160 as a collection tool 63- 64 D. ... Sharlow" J.A. "I agree. ...
FCA
Canada (National Revenue) v. Al Saunders Contracting & Consulting Inc., 2020 FCA 89
AL SAUNDERS CONTRACTING & CONSULTING INC. APPEAL DEALT WITH IN WRITING WITHOUT appearance of the parties REASONS FOR JUDGMENT BY: DAWSON J.A. ... LOCKE J.A. DATED: MAY 15, 2020 WRITTEN REPRESENTATIONS BY: Valerie Meier Allan Mason For The Appellant SOLICITORS OF RECORD: Nathalie G. Drouin Deputy Attorney General of Canada For The Appellant Felesky Flynn LLP Calgary, Alberta For The Respondent ...
FCA
D & J Driveway Inc. v. Canada (Minister of National Revenue), 2003 FCA 453
D & J Driveway Inc. v. Canada (Minister of National Revenue), 2003 FCA 453 Date: 20031127 Docket: A-512-02 Citation: 2003 FCA 453 CORAM: DÉCARY J.A. ... Tr., LL.L. FEDERAL COURT OF APPEAL SOLICITORS OF RECORD FILE: A-512-02 STYLE OF CAUSE: D & J DRIVEWAY v. ... REASONS FOR JUDGMENT OF THE COURT: LÉTOURNEAU J.A. DATE OF REASONS: NOVEMBER 27, 2003 APPEARANCES: Lyne Thériault and Marie-Hélène Montminy FOR THE APPLICANT Martin Gentile and Alain Gareau FOR THE RESPONDENT SOLICITORS OF RECORD: Pouliot, L'Écuyer FOR THE APPLICANT Sainte-Foy, Quebec Department of Justice- Canada FOR THE RESPONDENT Montréal, Quebec ...
FCA
Fletcher Leisure Group Inc. v. Deputy Minister of National Revenue (Customs & Excise), [1997] 1 CTC 2407
Deputy Minister of National Revenue (Customs & Excise), [1997] 1 CTC 2407 Hugessen J.A.: — Section 15 of the Special Import Measures Act sets out the general rule for the calculation of “normal value” Subject to sections 19 and 20, where goods are sold to an importer in Canada, the normal value of the goods is the price of like goods when they are sold by the exporter of the first mentioned goods (a) to purchasers (i) with whom the exporter is not associated at the time of the sale of the like goods, and... ...
FCA
The Queen v. Coopers & Lybrand Ltd., 80 DTC 6281, [1980] CTC 367 (FCA)
Its findings were not reassuring and meetings were held at which were present representatives of the Bank and Coopers & Lybrand. ... On September 24, 1976 the bank delivered to the respondent, a company performing services as receiver and an affiliate of the accounting firm of Coopers & Lybrand, a letter of appointment in the following terms: “September 24, 1976’’ Coopers & Lybrand Limited, 145 King Street West, Toronto, Ontario. ... Yours very truly, COOPERS & LYBRAND LIMITED Receiver and Manager Robert E Lowe, President. ...
FCA
The Queen v. B.B. Fast & Sons Distributors, 86 DTC 6106, [1986] 1 CTC 299 (FCA)
Fast & Sons Distributors, 86 DTC 6106, [1986] 1 CTC 299 (FCA) Urie, J. ... DeFehr & Sons, as a furniture merchant. The shareholdings in the respondent were at all material times as follows: William Fast 100 shares (20 per cent) Dr. ... Only one of the members of the group owned that 20% and one human individual of a group — even a group of two — cannot be equated with the whole group. ...
FCA
Newfoundland Light & Power Co. Ltd. v. The Queen, 90 DTC 6166, [1990] 1 CTC 229 (FCA)
Newfoundland Light & Power Co. Ltd. v. The Queen, 90 DTC 6166, [1990] 1 CTC 229 (FCA) Desjardins, J.A.: — The appellant, a Newfoundland company based in St. ... ", [13] or ”... the total cost to a taxpayer of acquiring a depreciable asset... ... Terms of payment: % of the monthly estimates submitted and accepted, the balance namely %, 35 days after final approval of the work by the architect. 5. ...
FCA
Tom Baird & Associates Ltd. v. Minister of National Revenue, [1998] 1 CTC 69
Tom Baird & Associates Ltd. v. Minister of National Revenue, [1998] 1 CTC 69 Létourneau J.A.: Once again, we are thrown back into the quagmire of the Excise Tax Act. ... I need only refer to this passage of Major J. of the Supreme Court of Canada in the recent case of Friesen v. /?. ... Wampole & Co. [10] as well as in British Columbia Telephone Co. v. ...