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FCTD

GSW Appliances Limited v. Her Majesty the Queen, [1993] 2 CTC 325

Section 2.1 reads as follows: 2.1 Purchase and Sale of the Acquired assets Upon and subject to the terms and conditions hereof, GSWS shall sell, transfer, assign and deliver to the company, and the company shall purchase and acquire, at the closing (but with effect as of the effective date), all of the property and assets (other than excluded assets) of GSWS's major appliance operations (hereafter collectively called the cquired assets"). ...
FCTD

H.B. Fenn and Company Ltd. v. Her Majesty the Queen, [1992] 2 CTC 49

The carrier was the Norfolk and Western Railway Company which contacted Donna MacCullouch, Office Manager in Welland of Livingston International (a subagent for the plaintiff's customs broker, the latter being Hemisphere Freight & Brokerage Services Inc. of Toronto). ...
FCTD

Crestbrook Forest Industries Ltd. v. Her Majesty the Queen, [1991] 2 CTC 195, 91 DTC 5521

Thomson & Associates Ltd. of Victoria, B.C., to make a survey of pulp and newsprint pricing discounts and commissions in that industry. ...
FCTD

Her Majesty the Queen v. Robert Duncan and Stephen Petroff, [1991] 2 CTC 360, 91 DTC 5615

.), enunciated the test to be met with respect to the previous subsection 225.2(1): ”... the issue is not whether the collection per se is in jeopardy but rather whether the actual jeopardy arises from the likely delay in the collection thereof. ...
FCTD

Lloyd Youngman v. Her Majesty the Queen, [1986] 2 CTC 475, 86 DTC 6584

The evaluation formula was set out in Schedule “A” of the defence as follows: Corporation's Equity in the residence $316,135.79 Return on investment of $316,135.79 at 9% $28,452.00 Mortgage interest, municipal taxes and insurance paid by the corporation 8,799.00 Gross Benefit to Plaintiff and wife received from corporation 37,251.00 Less: Amount of benefit attributable to Plaintiff’s wife 18,625.00 Amount of benefit attributable to Plaintiff 18,625.00 Less: Rent and expenses paid by Plaintiff 12,100.00 Net amount of benefit to the Plaintiff $ 6,526.00 The final assumption was that the corporation did not build the residence for the purpose of producing or gaining income from a business or property. ...
FCTD

Albert Manley v. Her Majesty the Queen, [1984] CTC 8, 83 DTC 5440

In this case the damages were calculated by reference to two per cent of the purchase price of the Levy shares what Manley would have been paid if the rest of the Levy group had been bound by the transaction between the plaintiff and Ben Levy. ...
FCTD

Morbane Developments LTD v. Minister of National Revenue, [1981] CTC 490, 81 DTC 5362

Its shares were held equally by two groups that of Mr Max Tanenbaum and that of Mr William McLachlan. 2. ...
FCTD

Olympia Interiors Ltd. v. R., [1997] 2 CTC 70

Attached hereto and marked exhibit “C” to this my affidavit are true copies of pgs. 48 & 49 of the examination. 4. ...
FCTD

SMC Pneumatics (Canada) Ltd. v. M.N.R., [1997] 2 CTC 321

(my emphasis) Facts On February 22, 1990, the Secretary of the Machinery & Equipment Advisory Board (MEAB) signed an Application for Duty Remission under the Machinery Program (Application #2037644), submitted by W.C.I. ...
FCTD

Braceland v. Revenue Canada Fairness Group Appeals, [1999] 3 CTC 343, 99 DTC 5189

Beaulac:-Points #1, #2 & #4- These comments all deal with taxation year prior to 1994. ...

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