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TCC
Ferme Jules Côté & Fils Inc. v. Her Majesty the Queen and Jules Côté v. Her Majesty the Queen, [1996] 3 CTC 2361 (Informal Procedure)
Ferme Jules Côté & Fils Inc. v. Her Majesty the Queen and Jules Côté v. ... He said Ferme Jules Côté & Fils Inc. had a turnover of some $1 million and an audited accounting system. ... Proulx found no trace of these purchases in the books of Ferme Jules Côté & Fils Inc. or in Mr. ...
T Rev B decision
B B Fast & Sons Distributors LTD v. Minister of National Revenue, [1982] CTC 2002, 82 DTC 1017
B B Fast & Sons Distributors LTD v. Minister of National Revenue, [1982] CTC 2002, 82 DTC 1017 Guy Tremblay:—This case was heard in Winnipeg, Manitoba on February 13, 1981. ... The Point at Issue The point at issue is whether or not the appellant, B B Fast & Sons Distributors Ltd and Willmar Window Industries Ltd were associated corporations during the 1975, 1976 and 1977 taxation years. ... H A Fawcett & Son, Limited v HMQ, [1979] CTC 303; 79 DTC 5224; affirmed by [1980] CTC 293; 80 DTC 6195; 10. ...
TCC
Ben Matthews & Associates Limited v. Minister of National Revenue, [1988] 1 CTC 2372, 88 DTC 1262
Ben Matthews & Associates Limited v. Minister of National Revenue, [1988] 1 CTC 2372, 88 DTC 1262 Rip, T.C.J. ... Robinette, Q.C., could not take the trial, retained another firm of lawyers, Greenspan & Moldaver. ... Scammell & Nephew, Ltd. v. Rowles, 22 T.C. 479; Usher's Wiltshire Brewery, Ltd., v. ...
FCTD
Deloitte Haskins & Sells, Receiver-Manager for Comanche Drilling Ltd. v. The Queen, 89 DTC 5225, [1989] 1 CTC 428 (FCTD)
Deloitte Haskins & Sells, Receiver-Manager for Comanche Drilling Ltd. v. ... Coopers & Lybrand Ltd., [1981] 2 F.C. 169; [1980] C.T.C. 367, 406; 80 D.T.C. 6281. A detailed analysis of the Coopers & Lybrand case is essential before arriving at a decision. ...
FCTD
Her Majesty the Queen v. Marsh & McLennan Limited, [1981] CTC 410, 81 DTC 5307
There was no evidence for the plaintiff and one witness for the defendant, John Charles Meuller, chief financial officer of the defendant Marsh & McLennan, Limited. the defendants Harry Price and Hillborn Insurance Limited in related action number T-3556-79, are wholly-owned subsidiaries of Marsh & McLennan, Limited, so that evidence and argument and judgment in this matter apply equally to them. ... I am conscious that the Company likely would not have been overjoyed at such a result, and obviously chose a normal course — to obtain maximum revenue. ... In my view, the conclusions of the Board in the March Shipping matter were entirely valid and were properly relied upon in deciding the Marsh & McLennan matter as it did. ...
FCA
Tom Baird & Associates Ltd. v. Minister of National Revenue, [1998] 1 CTC 69
Tom Baird & Associates Ltd. v. Minister of National Revenue, [1998] 1 CTC 69 Létourneau J.A.: Once again, we are thrown back into the quagmire of the Excise Tax Act. ... I need only refer to this passage of Major J. of the Supreme Court of Canada in the recent case of Friesen v. /?. ... Wampole & Co. [10] as well as in British Columbia Telephone Co. v. ...
TCC
Roberge & Fils Inc. v. The Queen, docket 95-3417-IT-G
Roberge & Fils Inc. v. The Queen, docket 95-3417-IT-G Date: 19980715 Docket: 95-3417-IT-G BETWEEN: eROBERGE & FILS INC., Appellant, and HER MAJESTY THE QUEEN, Respondent. ... 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. ...
TCC
A. & M. Johnson Contracting Ltd. v. The Queen, docket 96-4072-IT-G
& M. Johnson Contracting Ltd. v. The Queen, docket 96-4072-IT-G Date: 19980515 Docket: 96-4072-IT-G BETWEEN: A. & M. JOHNSON CONTRACTING LTD., Appellant, and HER MAJESTY THE QUEEN, Respondent. ... Subsection 152(6) seems to impose some obligation on the Minister because the operative clause begins with the words “the Minister shall reassess... ”. ...
FCTD
Handy & Harman of Canada Ltd. v. MNR, 73 DTC 5401, [1973] CTC 507 (FCTD)
Handy & Harman of Canada Ltd. v. MNR, 73 DTC 5401, [1973] CTC 507 (FCTD) Heald, J:—This is an appeal from a reassessment by the respondent of the appellant’s income tax for the taxation year ended December 31, 1967. ... The market price for silver is announced each day at noon, by Handy & Harman, appellant’s parent company, in New York. ... This table reads as follows: HANDY & HARMAN OF CANADA LIMITED SILVER PRICES AND VALUES 1946—JUNE 1967 $ PER OZ. ...
FCTD
Orenstein & Partners Inc. In Its Capacity as Court-Appointed Receiver of the Part Viii Tax Refund of Scannar Industries Inc. And Scannar Industries Inc. v. Her Majesty the Queen, [1994] 1 CTC 215
Orenstein & Partners Inc. In Its Capacity as Court-Appointed Receiver of the Part Viii Tax Refund of Scannar Industries Inc. ... The plaintiff, Orenstein & Partners Inc. (Orenstein), is the Court-appointed receiver of the Part VIII tax refund allegedly owing to the other plaintiff, Scannar Industries Inc. ... Finally, the plaintiffs argue that the decision of the Associate Senior Prothonotary was based on the view that the defendant's objections are based on the notion of estoppel — that is that the plaintiffs are estopped from relying on the application of subsection 194(4.2) — and that this is an argument that should more properly be considered by the trial judge (Plaintiffs’ Outline, supra, paragraphs 10 and 23). ...