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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. ...
TCC
Richard Perren & Co. v. R., [1997] 2 CTC 2501, 97 DTC 1227
Richard Perren & Co. v. R., [1997] 2 CTC 2501, 97 DTC 1227 Brulé T.CJ.: These two appeals were heard on common evidence and involve a payment made to Richard Perren in 1989. ... In reassessing the Appellant’s income the Minister has included the following amounts: The Appellant understands that these personal reassessments relate to the Minister’s treatment of $142,800 ($120,000 U.S.) deposited in the U.S. dollar account of Richard Perren & Company Inc. ...
TCC
Seaway-Levy Technical & Financial Limited v. Minister of National Revenue, [1991] 1 CTC 2260, 91 DTC 323
Seaway-Levy Technical & Financial Limited v. Minister of National Revenue, [1991] 1 CTC 2260, 91 DTC 323 Sarchuk, T.C.J.:—The appeals of Seaway-Levy Technical & Financial Ltd. (Seaway) are from reassessments of tax with respect to its 1981, 1982 and 1983 taxation years. ... The appellant was incorporated in 1916 and until 1976 was known as Canadian Acme Screw & Gear Ltd. ...
TCC
Laurent Goulet & Fils Inc. v. Minister of National Revenue, [1992] 1 CTC 2419, 92 DTC 1610
It contains, inter alia, the following: LESSEE: Laurent Goulet & Fils Inc. ... Lagueux & Frères Inc., [1974] C.T.C. 687, 74 D.T.C. 6569 (F.C.T.D.); 5. ... Burns Sand & Gravel Ltd. v. M.N.R., [1968] Tax A.B.C. 218, 68 D.T.C. 226; 8. ...
TCC
Granby Construction & Equipment Ltd. v. Minister of National Revenue, [1989] 2 CTC 2239, 89 DTC 456
Granby Construction & Equipment Ltd. v. Minister of National Revenue, [1989] 2 CTC 2239, 89 DTC 456 Lamarre Proulx, T.C.J. ... The question in issue is whether the appellant was right in establishing that debts owed to it by Amix Salvage & Sales Ltd. ... Harvey & Company Limited v. M.N.R., [1988] 1 C.T.C. 2209; 88 D.T.C. 1164, and Romualdo Berretti v. ...
TCC
Plaskett & Associates Limited v. Minister of National Revenue, 91 DTC 162, [1991] 1 CTC 2162 (TCC)
Plaskett & Associates Limited v. Minister of National Revenue, 91 DTC 162, [1991] 1 CTC 2162 (TCC) Sobier,T.CJ. ... In particular, she referred to In re Stuart & Sutterby (1929), 2 C.B.R. 1 (Ont. ... This decision was appealed to the Supreme Court of Ontario and reported as In re Stuart & Sutterby (1930), 2 C.B.R. 279. ...
TCC
Majestic Tool & Mold Limited v. Her Majesty the Queen (Informal Procedure), [1993] 2 CTC 2813
Majestic Tool & Mold Limited v. Her Majesty the Queen (Informal Procedure), [1993] 2 CTC 2813 Kempo, T.C.CJ. ... & M. Investments Ltd., Mr. Boggs prepared unaudited combined statements for fiscal year endings of October 31, 1989 and 1990. ... Financial statements were forwarded to Dun & Bradstreet by him which included mention of the term deposits as assets. ...
TCC
Sharon Buckland v. Minister of National Revenue and Donald Buckland and D.]. Buckland & Associates Ltd. (Third Parties) v. Minister of National Revenue, [1991] 1 CTC 2022, 91 DTC 131
Buckland & Associates Ltd. (Third Parties) v. Minister of National Revenue, [1991] 1 CTC 2022, 91 DTC 131 Brulé, T.C.J. ... Buckland & Associates Ltd. as third parties to the appeal. In his successful application the Minister requested a determination of the following questions: (1) Does the amount of $14,024 paid to Sharon Buckland by the company constitute income from employment? ...
TCC
Roberge & Fils Inc. v. R., [1999] 2 CTC 2509, 99 DTC 212
Roberge & Fils acted only as a “vehicle” for the eventual transfer to 2745-8017 Québec Inc. What is more, the hypothec held by Roberge & Fils Inc. could have been challenged, as therefore could the giving in payment. ... In a sale the extinction of the debt of the former creditor is only incidental, while in a viving in payment it i the primary result sought he ¢. ...
TCC
L. & R. Asphalt Ltd. v. Minister of National Revenue, [1989] 1 CTC 2370
& R. Asphalt Ltd. v. Minister of National Revenue, [1989] 1 CTC 2370 Sarchuk, T.CJ.:— The appellant L & R Asphalt Ltd. appeals from a reassessment of income tax for its 1985 taxation year. ... Nomad Sand & Gravel Ltd., [1987] 2 C.T.C. 112; 87 D.T.C. 5343. Counsel for the respondent argued that the Feeder does not in any reasonable fashion fit the definition of "property" set out in Class 22 of the Regulations. ... You don't use it to, say, move gravel from a pit to a location down the road, you don't hook it on to the back of the truck and — A. ...