Search - 包建铎违纪违法案件以案促改以案促治专题组织生活会 个人对照检查

On November 13, 1980, Revenue Canada issued a notice to Paramount Pictures Corporation (Canada) Ltd. showing total instalment payments of $1,042,000 ($792,000 + $250,000) which had been credited to account number 7-949-811-9. ... & Communikon Services Ltd. on July 31, 1979. This new corporation carried on business under the name Paramount Pictures Corporation (Canada) Ltd. with the first fiscal period ending 22-02-80. ...

—On ex parte application by the Minister, a judge may, subject to such conditions as he considers appropriate, authorize the Minister to impose on a third party a requirement under subsection (1) relating to an unnamed person or more than one unnamed person (in this section referred to as the " roup”) where the judge is satisfied by information on oath that (a) the person or group is ascertainable; (b) the requirement is made to verify compliance by the person or persons in the group with any duty or obligation under this Act; (c) it is reasonable to expect, based on any grounds, including information (statistical or otherwise) or past experience relating to the group or any other persons, that the person or any person in the group may have failed or may be likely to fail to provide information that is sought pursuant to the requirement or to otherwise comply with this Act; and (d) the information or document is not otherwise more readily available. (4) Service of authorization. ... Canada, [1990] 1 S.C.R. 627; [1990] 2 C.T.C. 103; 90 D.T.C. 6243, at 109 (D.T.C. 6247; S.C.R. 639), Madam Justice Wilson recalled the proper construction to be given to subsection 231(3) of the Income Tax Act‘, which is the predecessor to subsection 231.2(1): This Court had occasion to consider subsection 231(3) of the Act in James Richardson & Sons, Ltd. v. ...

Ct.) and Racine, Demers & Nolin v. M.N.R., [1965] C.T.C. 150, 65 D.T.C. 5098 (Ex. ... The provision now reads as follows: 220(3.1) Waiver of penalty or interest. — The Minister may at any time waive or cancel all or any portion of any penalty or interest otherwise payable under this Act by a taxpayer or partnership and, notwithstanding subsections 152(4) to (5), such assessment of the interest and penalties payable by the taxpayer or partnership shall be made as is necessary to take into account the cancellation of the penalty or interest. ...

Appeal allowed. 69; MNR v John Colford Contracting Co Ltd, [1960] Ex CR 433, aff'd by SCR 1962; [1960] CTC 178; 60 DTC 1131; The Queen v Imperial General Properties Ltd, [1985] 1 CTC 40; 85 DTC 5045; Isaac Holden & Sons Ltd v CIR, 12 TC 768; Kenneth B S Robertson Ltd v MNR, [1944] Ex CR 170; [1944] CTC 75; 2 DTC 655; Maple Leaf Mills Ltd v MNR, [1977] 1 S.C.R. 558, [1976] CTC 324; 76 DTC 6182; CIR v Newcastle Breweries Ltd, 12 TC 927; The Naval Colliery Co Ltd v CIR, 12 TC 1017; MNR v Shofar Investment Corp, [1979] CTC 433; 79 DTC 5347; Willingale (Inspector of Taxes) v International Commercial Bank Ltd, [1978] 1 All ER 754 (HL); M H Courrier Inc v The Queen, [1976] CTC 567; 76 DTC 6331; MNR v Benaby Realties Ltd, [1967] CTC 418; 67 DTC 5275; Edmonton Liquid Gas Ltd v The Queen, [1984] CTC 536; 84 DTC 6526; Francon Ltée v The Queen, [1973] CTC 708; 73 DTC 5514. 1 *SC 1970-71-72, c 63, telle qu'amendée. 2 *En l’occurrence, le deuxième paragraphe non chiffré de l’article 7. 3 ★Associated Investors of Canada Ltd v MNR, [1967] CTC 138; 67 DTC 5096; MNR v Atlantic Engine Rebuilders Ltd, [1967] S.C.R. 477; [1967] CTC 230; 67 DTC 6155; Cana dian Fruit Distributors Ltd v MNR, [1954] CTC 284; 54 DTC 1145; Canadian General Electric Co Ltd v MNR, [1962] S.C.R. 3; [1961] CTC 512; 61 DTC 1300; Commonwealth Construction Co Ltd v The Queen, [1984] CTC 338; 84 DTC 6420; Dominion Taxicab Association v MNR, [1954] CTC SCR 42; [1954] CTC 34; 54 DTC 1020; Alger B Ferriss v MNR, [1965] 2 Ex CR 525; [1964] CTC 491; Freeway Properties Inc v The Queen, [1985] 1 CTC 222; 85 DTC 5183; CIR v Gardner, Mountain & d'Ambrumenil Ltd, [1947] 29 TC 4-[Maple Leaf Mills Limited c MNR, [1977] 1 RCS 558, à la page 566; [1976] CTC 324 à la page 330. 5 ^Canadian Fruit Distributors Limited c MNR, [1954] CTC 284, à la page 292; 54 DTC 1145 à la page 1149. ...

There is a staff of 39 teachers for the pupil population — a ratio of 20 to 1. ... Lord Watson in Salomon v Salomon & Co, [1897] AC 22 has said at 38: “Intention of the legislature” is a common but very slippery phrase, which, popularly understood, may signify anything from intention embodied in a positive enactment to speculative opinion as to what the legislature probably would have meant, although there has been an omission to enact it. ...

There is, of course, no room for debate on * This was the Canada-Germany Income Tax Agreement in issue. the proposition that Parliament is supreme and can neither bind itself nor any successor of Parliament when acting within its constitutionally-assigned sovereign jurisdiction. obviously it follows that section 3 or any other part of the 1956 statute can be repealed or amended. ... It is interesting to note that an extract from Michael Edwardes-Ker, The International Tax Treaties Service, pages 30-32 refers to a decision June 1979, in ” International Tax Treaties O.E.C.D. ...

.: — These two applications came on for hearing in Fredericton, New Brunswick, on April 11, 1996 at which time I reserved my decision. ... Canada (Minister of National Health & Welfare), 50 D.L.R. (4th) 44, 84 N.R. 163 (C.A.), and in Wilder v. ...

(See Canada (Minister of Employment & Immigration), v. Lidder, [1992] 2 F.C. 621, 136 N.R. 254 (F.C.A.), reversing (1987), 3 Imm. ... (See GRS Tool & Die Inc. v. The Deputy Minister of Revenue for Customs and Excise (1981), 7 T.B.R. 313, 3 C.E.R. 109 (T.B.)) 2. ...

(First, Second & Third) v. M.N.R., [1969] C.T.C. 134, 69 D.T.C. 5109, at page 155 (D.T.C. 5121) (Ex. ... Canada (Minister of Employment and Immigration), [1989] 3 F.C. 16, 61 D.L.R. (4th) 313 (C.A.); Re Preston, [1985] A.C. 835 (H.L.). 8 ®See, for example, Pioneer Laundry & Dry Cleaners Ltd. v. ...

As the expression that's been used in the Court before, in a broad sense there is a double taxation, but not — Q. ... Armstrong & Co., [1970] C.T.C. 175, 70 D.T.C. 6148 (Exch. Ct.), which distinguished Wampole. ...