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TCC

Hanover Management Ltd. & Candor Investments Ltd. v. Minister of National Revenue, [1989] 2 CTC 2076, 89 DTC 355

& Candor Investments Ltd. v. Minister of National Revenue, [1989] 2 CTC 2076, 89 DTC 355 Kempo, T.C.J. ... May 1978 “Keg Building” 605-11th Avenue S.W., Calgary Renovate and rent. b. ... Fall 1978 to mid 1979 "Petro Canada Land" 101-6th Avenue S.W., Calgary Land accumulation/assembly Redevelopment project. d. ...
TCC

Northwood Pulp & Timber Ltd. v. R., [1996] 2 CTC 2123, 96 DTC 1104

Justice MacGuigan in West Kootenay Power & Light Co. v. R., (sub nom. ... Nomad Sand & Gravel Ltd. v. Canada), [1991] 1 C.T.C. 60, (sub nom. ... In the case of Newfoundland Light & Power Co. v. R., (sub nom. Newfoundland Light & Power Co. v. ...
SCC

Deputy Minister of National Revenue, Customs and Excise v. MacMillan & Bloedel (Alberni) Ltd., [1965] SCR 366

Richard, for the responend MacMillan & Bloedel (Alberni) Ltd. J. B. ... Solicitors for the respondent, MacMillan & Bloedel (Alberni) Ltd.: Gowling, MacTavish, Osborne & Henderson, Ottawa. Solicitors for the respondent, Ontario-Minnesota Pulp & Paper Ltd.: Fraser, Beatty, Tucker, Mclntosh & Stewart, Toronto. ...
TCC

Milan Hrovat, M & H Doors LTD v. Minister of National Revenue, [1983] CTC 2662, 83 DTC 590

In the instant matter, the applicant, Milan Hrovat, did not appear he apparently could not, due to a medical problem. However, both of the partners of the accounting firm Folkard & Co, a Mr Rupert N Folkard, CA, and Mr Sam Ramessar, CA, did give testimony. ... The Minister’s assertion must be directed, therefore, toward the second issue the involvement of the agents, Folkard & Co. ...
TCC

Ergorecherche & Conseils Inc. v. R., [1998] 3 CTC 2062, [1998] DTC 1710

Paragraph 37(1)(a) of the Act refers to an expenditure of a current nature made on SR & ED. Paragraph 37(8)(«) of the Act provides that expenditures on or in respect of SR & ED are expenditures directly attributable to the prosecution of SR & ED. ... However, how can a salary paid on the basis of a business’ liquid assets be connected with SR & ED? ...
SCC

International Iron & Metal Co. Ltd. v. Minister of National Revenue, 72 DTC 6205, [1972] CTC 242, [1974] SCR 898, aff'g 69 DTC 5445, [1969] CTC 668 (Ex Ct)

International Iron & Metal Co. Ltd. v. Minister of National Revenue, 72 DTC 6205, [1972] CTC 242, [1974] S.C.R. 898, aff'g 69 DTC 5445, [1969] CTC 668 (Ex Ct) Supreme Court of Canada International Iron & Metal Co. ... Ministre du Revenu National, [1974] S.C.R. 898 Date: 1972-05-01 International Iron & Metal Co. ...   [1] [1967] S.C.R. 223, at p. 227. [2] [1968] S.C.R. 193, at p. 197. ...
EC decision

L. Berman & Co. Ltd. v. Minister of National Revenue, [1961] CTC 237, 61 DTC 1150

& S. duty September 10, 1957, $1,600.00, making a total of $5,067.42; March 31, 1956, to United China & Glass, $2,620.35, plus Canada S.S. Lines $219.23, plus Samson & Shaen, $1,302.61, making a total of $4,142.19; and June 6, 1956, to Shore & Coggins, $998.75. ... Wild, $1,570.09; and on July 6, 1956, to Shore & Coggins, $998.75. ...
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... ...
FCTD

Day & Ross v. The Queen, 76 DTC 6433, [1976] CTC 707 (FCTD)

Day & Ross v. The Queen, 76 DTC 6433, [1976] CTC 707 (FCTD) Dubé, J:—These are appeals from reassessments made by the Minister of National Revenue for the taxation years 1966, 1967, 1968, 1969, 1970 and 1971. ... The English Court of Appeal in Commissioners of Inland Revenue v Alexander Von Glehn & Co, Ltd, 12 TC 232, disallowed the deduction of a compromise penalty paid by the respondent company in respect of alleged infringements of the Customs (War Powers) Act, 1915, 5 Geo V, c 31. ... In the case of Minister of Finance v Smith, [1927] AC 193; [1917-27] CTC 251, wherein it was held that upon a literal construction of the Act the profits in question, though by law of the particular province they are illicit, come within the words employed in Section 3(1), Lord Haldane in his remarks said at page 197, in fine [[1917-27] CTC 254]: “... ...
T Rev B decision

Kruger Pulp & Paper Ltd. v. Minister of National Revenue, [1975] C.T.C. 2323, 75 D.T.C. 245

Of this amount the payments made to Lamontagne & Lamontagne were again dropped by the appellant as were amounts totalling $950 paid to Eric M Lack, Notary, and to the firm of O'Brien, Hall & Nolan. In issue was an amount of $1,964.23 in Canadian currency paid to Hamburger & Green, Counsel lors at Law. ... Exhibit A- 7 is a bill for $600 from O'Brien, Home, Hall, Nolan, Saunders, O'Brien & Smyth, Barristers & Solicitors, and deducted by the appellant, $200 of which was disallowed because it dealt with the St Felicien project. ...

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