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SCC
International Harvester Co. of Canada v. The Provincial Tax Commission, [1941] SCR 325
"Income" was defined (in part) as "the annual net profit or gain * * * as being profits * * * received by a person * * * from any trade, manufacture or business * * * whether derived from sources within Saskatchewan or elsewhere. ... By section 3, income is defined; and income of the kind we are considering, profits of a business, is "profits *. * * received by a person * * * from any trade, manufacture or business * * * whether derived from sources within Saskatchewan or elsewhere. ... In section 4 it is enacted:— The following incomes shall not be liable to taxation hereunder: *** (m) profits earned by a corporation or joint stock company * * * in that part of its business carried on at a branch or agency outside of Saskatchewan. ...
SCC
Mathew v. Canada, 2005 DTC 5538, 2005 SCC 55, [2005] 2 SCR 643
Canada, 2005 DTC 5538, 2005 SCC 55, [2005] 2 S.C.R. 643 SUPREME COURT OF CANADA Citation: Mathew v. ... Canada, [2002] 2 F.C. 288, 2001 FCA 260. Statutes and Regulations Cited Income Tax Act, R.S.C. 1985, c. 1 (5th Supp .), ss. 18(13) , 96 , 245(1) to (4) , 248(10) . ... Pitfield $ 55,000-$ 468,845 C. C. Sturrock $ 88,000-$ 750,152 Total Class A $ 1,503,334 -$ 12,815,020 Class B TFTI $ 2-$ 2,095,377 NSFC $ 1-$ 523,844 Kaulius $ 1-$ 523,844 Total Class B $ 4 -$ 3,143,065 Total Class A and B $ 1,503,338-$ 15,958,085 24 During the relevant period, neither Partnerships A nor B ever acquired or sold any property other than the Portfolio Assets. 25 By September 30, 1993, as a result of the sale of some of the Portfolio Assets and the write-down of the remaining assets to fair market value, Partnership A realized losses in excess of $52 million. ...
SCC
Canada v. Canada North Group Inc., 2021 SCC 30, [2021] 2 SCR 571
(Abella J. concurring) Dissenting Reasons: (paras. 254 to 265) Moldaver J. ... Minister of National Revenue ” (2004), 45 C.B.R. (4th) 244. ... JJ. were delivered by Côté J. — I. ...
SCC
The Queen v. Jennings et al., [1966] SCR 532
Highways — Duty to keep highway in repair — Failure to maintain stop sign in proper position — Plaintiff injured in collision at intersection — Liability of Department — The Highway Improvement Act, R.S.O. 1960, c. 171, s. 33. ... [Page 533] The Department ’ s appeal and C ’ s cross-appeal were dismissed. ... He allowed: Out of pocket expenses to the date of trial, agreed upon, $ 13,801.53 Loss of salary to date of trial 33,800.00 Additional expenses for upkeep of son............................................................ 600.00 Expenses of appointing Committee................................................................. 529.00 Estimated hospital expenses for 5 years from date of trial 20,075.00 Estimated medical ’ expenses for 5 years from date of trial 2,600.00 Estimated loss in connection with options to purchase stock 18,590.00 The present value at the date of the trial of Jennings ’ loss of salary for the ensuing 5 years after deducting estimated income tax from gross earnings.............................................................................................................................. 104,000.00 Loss of enjoyment of life..................................................................................... 2,000.00 These items total $195,995.53, but apparently there was some correction not appearing in his reasons as the total arrived at by the learned trial judge was $195,795.53. ...
SCC
D.I.M.S. Construction inc. (Trustee of) v. Quebec (Attorney General), 2005 SCC 52, [2005] 2 SCR 564
R‑20, s. 54 — Bankruptcy and Insolvency Act, R.S.C. 1985, c. B-3, ss. 97(3) , 136 to 147 . ... C-20, s. 11. Bankruptcy and Insolvency Act, R.S.C. 1985, c. B-3, ss. 30(1) (d), 67(1) , 71(2) , 97(3) , 121 , 135 , 136 to 147 . ... English version of the judgment of the Court delivered by Deschamps J. — 1. ...
SCC
Moufarrège v. Quebec (Deputy Minister of Revenue), 2005 DTC 5605, [2005] 2 S.C.R. 598, 2005 SCC 53
Quebec (Deputy Minister of Revenue), 2005 DTC 5605, [2005] 2 S.C.R. 598, 2005 SCC 53 SUPREME COURT OF CANADA Citation: Moufarrège v. ... Richard Moufarrège Respondent Official English Translation Coram: McLachlin C.J. and Major, Bastarache, Binnie, LeBel, Deschamps and Charron JJ. ... on appeal from the court of appeal for quebec Income tax – Deduction – Interest – Interest paid on loan used to earn income from business or property – Source of income ceasing to exist – Interest not deductible – Taxation Act, R.S.Q., c. ...
SCC
Century Services Inc. v. Canada (Attorney General), 2011 DTC 5006 [at at 5511], [2010] 3 S.C.R. 379, 2010 SCC 60
C-36, s. 18.3(1) — Excise Tax Act, R.S.C. 1985, c. E-15, s. 222(3) . ... E‑15, s. 222 . Income Tax Act, R.S.C. 1985, c. 1 (5th Supp .), ss. 227(4) , (4.1) . ... B-3 (“ BIA ”) provision confirming ― or explicitly preserving ― its effective operation ...
SCC
Shell Canada Ltd. v. Canada, [1999] 3 SCR 616
Canada, [1999] 3 S.C.R. 616 Shell Canada Limited Applicant v. ... Canada File No.: 26596. 1998: December 16. Present: Binnie J. ... Cases Cited Referred to: R. v. Keegstra, [1995] 2 S.C.R. 381. Statutes and Regulations Cited Income Tax Act , R.S.C., 1985, c. 1 (5th Supp .). ...
SCC
N.R. Whittall v. Minister of National Revenue, [1968] SCR 413
John’s Trust Syndicate in 1952.................... $ 77,285.05 Less cost of same @ $1.00 per share............... 37,500.00 $ 39,785.05 for 1954 Proceeds from sale of shares of Inland Natural Gas Co. ... Particulars of the purchases and sales are as follows: Date Number Purchased Price Per Share Number Sold Sales Price Per Share 15 January 1954............... 16,500 2.48/2.70 13 May............................... 500 3.19 21 May............................... 2,100 2.30/2.50 1 June................................ 2,000 2.57/2.62 6 July.................................. 2,900 0.91/2.51½ 8 July.................................. 3,000 1.31/1.36 19 July................................ 1,000 1.16 17 September................... 2,000 1.95 27 September................... 2,000 2.02 19 October........................ 2,500 2.63 12 November.................... 2,500 2.01½ 23 November.................... 2,000 2.75/2.85 3 December...................... 1,000 2.68½ 6 December...................... 8,000 2.78½/2.83 7 December...................... 4,000 2.88½ Total........................ 18,000 34,000 On March 31, 1955, the appellant purchased a further 2,500 shares of Inland Natural Gas at $2.70 per share and on June 19, 1955, sold 2,500 shares of Inland Natural Gas at $3.40/3.50. ... The re-assessment is as follows: Profit on sale of shares of Yankee Princess Oils Ltd. from 29th January, 1952, to 21st April, 1952, as per schedule filed with respondent 105,250 shares.............................................................. $110,157.34 [Page 423] Less: Purchase of 31st January, 1952, shown as sale in error 500 share.............................................. 383.06 109,774.28 Add: Sale of 5th March, 1952, not included in schedule filed 2,000 shares........................................ 2,135.00 111,909.28 Less: Cost of shares sold 92,800.................................................. $6,750.00 13,950 @ 7½¢................................... 1,046.25 7,796.55 $104,113.03 The 106,750 shares in Yankee Princess Oils material to this appeal were acquired by the appellant upon three occasions: (a) 20,250 shares were acquired upon the incorporation of Yankee Princess Oils on September 24, 1948; (b) 65,000 shares were acquired in August 1951; (c) 40,000 shares were acquired on December 21, 1951. ...
SCC
Privacy Act (Can.) (Re), 2001 SCC 89, [2001] 3 SCR 905
(Re) Neutral citation: 2001 SCC 89. File No.: 27846. 2001: November 7; 2001: December 7. ... P‑21, s. 8 -- Customs Act, R.S.C. 1985, c. 1 (2nd Supp .), s. 108(1). ...