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FCTD (summary)
Coppley Noyes & Randall Ltd. v. The Queen, 91 DTC 5291, [1991] 1 CTC 541 (FCTD), varied on appeal 93 DTC 5196, 5508 (FCA). -- summary under Payment & Receipt
Coppley Noyes & Randall Ltd. v. The Queen, 91 DTC 5291, [1991] 1 CTC 541 (FCTD), varied on appeal 93 DTC 5196, 5508 (FCA).-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt presumed application to oldest debt The taxpayer's practice, in determining its allowance for doubtful accounts at the end of its taxation year on November 27, 1082, included having regard to payments made by trade debtors during the three months after that its year end, but treating receipts as going to the oldest receivables first. ...
FCTD (summary)
Western Union Insurance Co. v. The Queen, 83 DTC 5388, [1983] CTC 363 (FCTD) -- summary under Payment & Receipt
The Queen, 83 DTC 5388, [1983] CTC 363 (FCTD)-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt sending of cheque to sender's lawyers The sending of a cheque by the lender to (its) solicitors did not constitute the payment of a sum to the borrower. ...
FCTD (summary)
The Queen v. Ans, 83 DTC 5038, [1983] CTC 8 (FCTD) -- summary under Payment & Receipt
Ans, 83 DTC 5038, [1983] CTC 8 (FCTD)-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt receipt by set-off A company's shareholder was held to have received a bonus when the amount of the bonus payable by the company was credited against the balance outstanding on the loan by the company to the shareholder. ...
FCTD (summary)
The Queen v. Canadian-American Loan and Investment Corp. Ltd., 74 DTC 6104, [1974] CTC 101 (FCTD) -- summary under Payment & Receipt
., 74 DTC 6104, [1974] CTC 101 (FCTD)-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt receipt of sums collected by affiliate The taxpayer, which operated a boat storage business in a storage building, subleased a portion of the leased premises to an affiliate ("Georgia") with accumulated losses, but continued to operate the business the same as before. ...
FCTD (summary)
Mendels v. The Queen, 78 DTC 6267, [1978] CTC 404 (FCTD) -- summary under Payment & Receipt
The Queen, 78 DTC 6267, [1978] CTC 404 (FCTD)-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt payment by mutual book entry The taxpayer was partner with another dentist in the partnership for their professional practice and tey also jointly owned a corporation (the "Company"), which initially only leased laboratory and dental equipment to the partnership. ...
FCTD (summary)
Deloitte Haskins & Sells, Receiver-Manager for Comanche Drilling Ltd. v. The Queen, 89 DTC 5225, [1989] 1 CTC 428 (FCTD) -- summary under Subsection 227(9)
Deloitte Haskins & Sells, Receiver-Manager for Comanche Drilling Ltd. v. ... Unlike the Coopers & Lybrand case, funds were actually available to pay the remittances. ...
FCTD (summary)
R & S Industries Inc. v. Canada (National Revenue), 2016 FC 275 -- summary under Subsection 18.1(2)
R & S Industries Inc. v. Canada (National Revenue), 2016 FC 275-- summary under Subsection 18.1(2) Summary Under Tax Topics- Other Legislation/Constitution- Federal- Federal Courts Act- Section 18.1- Subsection 18.1(2) extension not granted due to unexplained lengthy delay and lack of substantive merit On September 1, 2005, the appellant (“R & S”) transferred its assets to a limited partnership (“BELP”) which was controlled by its controlling shareholder. ... On November 12, 2010 R & S filed a Notice of Objection asserting that a reassessment of its return for the taxation year of the transfer was based on amounts mistakenly provided on the previously-filed s. 97(2) election form. ... On August 8, 2014, CRA confirmed the reassessment, to which R & S filed a Notice of Objection. ...
FCTD (summary)
Coppley Noyes & Randall Ltd. v. The Queen, 91 DTC 5291, [1991] 1 CTC 541 (FCTD), varied on appeal 93 DTC 5196, 5508 (FCA). -- summary under Accounting Principles
Coppley Noyes & Randall Ltd. v. The Queen, 91 DTC 5291, [1991] 1 CTC 541 (FCTD), varied on appeal 93 DTC 5196, 5508 (FCA).-- summary under Accounting Principles Summary Under Tax Topics- General Concepts- Accounting Principles Before going on to affirm the deductibility under s. 20(1)(l) of an allowance for doubtful accounts which the taxpayer had taken for tax and financial statement purposes, Reed J. stated (p. 5297): "... in determining a reserve for doubtful debts, the principal factors that are used for the preparation line.gifl statements, as governed by the generally accepted accounting principles approved by the Canadian Institute of Chartered Accountants, are applicable, unless: (1) the Income Tax Act expressly requires otherwise or (2) the Income Tax Act implicitly requires otherwise. ...
FCTD (summary)
Coppley Noyes & Randall Ltd. v. The Queen, 91 DTC 5291, [1991] 1 CTC 541 (FCTD), varied on appeal 93 DTC 5196, 5508 (FCA). -- summary under Subsection 10(1)
Coppley Noyes & Randall Ltd. v. The Queen, 91 DTC 5291, [1991] 1 CTC 541 (FCTD), varied on appeal 93 DTC 5196, 5508 (FCA).-- summary under Subsection 10(1) Summary Under Tax Topics- Income Tax Act- Section 10- Subsection 10(1) consistent LIFO use generally is acceptable In commenting on the Anaconda case, Reed J. stated (p. 5298): "... ...
FCTD (summary)
The Queen v. Nomad Sand & Gravel Ltd., 87 DTC 5343, [1987] 2 CTC 112 (FCTD) -- summary under Class 10
Nomad Sand & Gravel Ltd., 87 DTC 5343, [1987] 2 CTC 112 (FCTD)-- summary under Class 10 Summary Under Tax Topics- Income Tax Regulations- Schedules- Schedule II- Class 10 A sand and gravel pit was not a "mine", and front end loaders used in the gravel pit operation accordingly were Class 22, rather than Class 10 assets. ...