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Decision summary

Kelly, Douglas & Co. Ltd. v. MNR, 76 DTC 1090 (T.R.B.) -- summary under Inventory

Kelly, Douglas & Co. Ltd. v. MNR, 76 DTC 1090 (T.R.B.)-- summary under Inventory Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Inventory Supplies of stationery and special forms on hand at the end of the year were not inventory because they had no market value at all and were of no use to anyone other than the taxpayer. ...
Decision summary

Crown Cork & Seal Canada Inc. v. The Queen, 90 DTC 6586 (FCTD) -- summary under Subsection 163(2)

Crown Cork & Seal Canada Inc. v. The Queen, 90 DTC 6586 (FCTD)-- summary under Subsection 163(2) Summary Under Tax Topics- Income Tax Act- Section 163- Subsection 163(2) The claiming by the corporation of CCA on an asset which had not yet been substantially completed was based on a misunderstanding of the kind of asset upon CCA could be taken. ...
Decision summary

Re Marks & Spencer Canada, Inc., 84 DTC 6037 (Nfld. S.C.) -- summary under Subsection 224(1)

Re Marks & Spencer Canada, Inc., 84 DTC 6037 (Nfld. S.C.)-- summary under Subsection 224(1) Summary Under Tax Topics- Income Tax Act- Section 224- Subsection 224(1) Since s. 224 is a garnishee provision that only binds or attaches the interest of the taxpayer, it does not apply to book debts that were assigned to a bank prior to the issuance of the s. 224 demand, notwithstanding that such issuance was effected prior to receipt by the taxpayer's debtor of notice from the bank of the assignment of book debts. ...
Decision summary

APL Oil & Gas Ltd. v. The Queen, 96 DTC 1666 (TCC) -- summary under Section 12

APL Oil & Gas Ltd. v. The Queen, 96 DTC 1666 (TCC)-- summary under Section 12 Summary Under Tax Topics- Statutory Interpretation- Interpretation Act- Section 12 An assessment that erroneously referred to the taxation year of the taxpayer as ending on January 2, 1987 rather than December 31, 1986 was deemed to be valid under s. 152(8) of the Income Tax Act, after a brief reference was made to s. 12 of the Interpretation Act. ...
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Customs & Excise Commissioners v. Automobile Association, [1974] 1 WLR 1447 (HL) -- summary under Supply

Customs & Excise Commissioners v. Automobile Association, [1974] 1 WLR 1447 (HL)-- summary under Supply Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Supply Upon paying for membership in the Automobile Association, a member was considered to be paying not for the mere privilege of membership but for the benefits that a member received under his contract with the Automobile Association and, accordingly, the subscription price is apportionable among those services and facilities received by each member. ...
Decision summary

Smith, Kline & French Laboratories Ltd. v. A.G. Can. (1987), 12 F.T.R. 81 -- summary under Interpretation Bulletins, etc.

Smith, Kline & French Laboratories Ltd. v. A.G. Can. (1987), 12 F.T.R. 81-- summary under Interpretation Bulletins, etc. ...
Decision summary

James Snook & Co., Ltd. v. Blasdale (1952), 33 T.C. 244 (CA) -- summary under Income-Producing Purpose

James Snook & Co., Ltd. v. Blasdale (1952), 33 T.C. 244 (CA)-- summary under Income-Producing Purpose Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Income-Producing Purpose The agreement for the sale of the shares in the capital of the taxpayer provided that the purchaser would cause the taxpayer to pay compensation for loss of office to directors of the taxpayer. ...
Decision summary

Warsh & Co. Ltd. v. MNR, 62 DTC 247 (TAB) -- summary under Evidence

Warsh & Co. Ltd. v. MNR, 62 DTC 247 (TAB)-- summary under Evidence Summary Under Tax Topics- General Concepts- Evidence Mr. ...
Decision summary

Parsons & Steiner v. MNR, 62 DTC 1148 (Ex Ct) -- summary under Compensation Payments

Parsons & Steiner v. MNR, 62 DTC 1148 (Ex Ct)-- summary under Compensation Payments Summary Under Tax Topics- Income Tax Act- Section 9- Compensation Payments capital receipt for cancellation of distributorship Compensation received by the taxpayer, which carried on the business of a manufacturer's agent and wholesale merchant in china and related wares, for the cancellation, after 18 years, of its agency arrangement for the distribution on commission of Doulton china in Canada, was a capital receipt. ...

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