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TCC

I.R.Q. Management Ltd. v. Minister of National Revenue, [1991] 1 CTC 2523, 91 DTC 792

The cephalometric diagnostic program being developed was in Queen's words ”... totally innovative in that there was no other such program on the market. ...
TCC

Veltri and Son Ltd., Lianna Developments Ltd. and 511060 Ontario Ltd. v. Minister of National Revenue, [1991] 1 CTC 2691, 91 DTC 862

In the French language version of the statute, the corresponding word is principaux”. ...
TCC

Fraser v. R., [1996] 2 CTC 2631 (Informal Procedure)

.: This is an appeal from an assessment of income tax made by the Minister of National Revenue (the “Minister”) on April 11, 1994 with respect to the appellant’s 1992 taxation year. ...
FCTD

Del Zotto v. R., [1996] 1 CTC 120, 95 DTC 5636

.: The plaintiff, Mr. Del Zotto, brings two motions. One is to amend the statement of claim pursuant to Rule 420. ...
FCA

Perrier Group of Canada Inc. v. Canada, [1996] 1 CTC 167

.: This appeal raises the same issues of law as are raised in Court File No. ...
TCC

Pinot Holdings Ltd. v. R., [1996] 1 CTC 2035, 96 DTC 1277

Under this agreement of purchase and sale the partnership agreed to pay the purchase price of $13,500,000 to Salloum Doak, Barristers & Solicitors, in trust, to be disbursed to the Bank of Montreal, the appellant’s creditor prior to the partnership, when clear title to the Capri assets was registered in the name of the partnership. 10. ...
TCC

Fingold v. R., [1996] 1 CTC 2772, 96 DTC 1305

.: The Appellant appeals from the assessments by the Minister of National Revenue (the “Minister”) for his 1988 and 1989 taxation years whereby the Minister added to his income, pursuant to subsection 15(1) of the Income Tax Act (the “Act”), the amounts of $374,000 for 1988 and $445,675 for 1989 as a shareholder’s benefit from Fobasco Limited (“Fobasco”) with respect to the use by the Appellant of a Florida condominium owned by Fobasco. ...
TCC

Guerette v. R., [1996] 1 CTC 2780 (Informal Procedure)

.: Before commencing with the evidence counsel for the Appellant made a motion for the change of name of the Appellant from Guerette to Barnard as she had married since the filing of the Notice of Appeal. ...
TCC

Flexi-Coil Ltd. v. R., [1996] 1 CTC 2941

However, as it has often been said in tax cases- although usually where the taxpayer was trying to qualify for a tax benefit and not, as here, where the taxpayer is trying to avoid an adverse tax consequence that bookkeeping entries do not create reality. ...
FCTD

Mervin Holizki v. Her Majesty the Queen, [1995] 2 CTC 420

Robertson had an arrangement with a law firm in Regina, Thauberger & Company, that where a client did not have a lawyer and wished to incorporate, they would use one of the Thauberger "shelf companies" to try to keep the costs manageable. ...

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