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EC summary
Blauer v. MNR, 71 DTC 5113, [1971] CTC 154 (F.C.T.A.), briefly aff'd 75 DTC 5076, [1975] CTC 112 (SCC) -- summary under Payment & Receipt
.), briefly aff'd 75 DTC 5076, [1975] CTC 112 (SCC)-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt post-dated cheque A post-dated cheque was payable for purposes of ss. 12(1)(l) and 76(1) on its date rather than the date of delivery. ...
Decision summary
Narich Pty. Ltd. v. Commissioner of Pay-roll Tax, [1984] BTC 8019 (PC) -- summary under Payment & Receipt
Commissioner of Pay-roll Tax, [1984] BTC 8019 (PC)-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt indirect receipt of wages An argument was rejected to the effect that fees received by employees of a company were not wages because they were collected directly from clients of the company. ...
FCTD (summary)
Western Union Insurance Co. v. The Queen, 83 DTC 5388, [1983] CTC 363 (FCTD) -- summary under Payment & Receipt
The Queen, 83 DTC 5388, [1983] CTC 363 (FCTD)-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt sending of cheque to sender's lawyers The sending of a cheque by the lender to (its) solicitors did not constitute the payment of a sum to the borrower. ...
TCC (summary)
Transalta Corporation v. The Queen, 2012 DTC 1106 [at at 3044], 2012 TCC 86 -- summary under Payment & Receipt
The Queen, 2012 DTC 1106 [at at 3044], 2012 TCC 86-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt past services Margeson J. accepted (at para. 99) that employees to whom the taxpayer issued shares in payment of bonuses to them gave consideration equal to the full value of those share "on the basis of past unremunerated services rendered to the Appellant. ...
FCTD (summary)
The Queen v. Ans, 83 DTC 5038, [1983] CTC 8 (FCTD) -- summary under Payment & Receipt
Ans, 83 DTC 5038, [1983] CTC 8 (FCTD)-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt receipt by set-off A company's shareholder was held to have received a bonus when the amount of the bonus payable by the company was credited against the balance outstanding on the loan by the company to the shareholder. ...
TCC (summary)
Johnson v. The Queen, 2010 DTC 1213 [at at 3568], 2010 TCC 321 (Informal Procedure) -- summary under Payment & Receipt
The Queen, 2010 DTC 1213 [at at 3568], 2010 TCC 321 (Informal Procedure)-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt frequent flyer points Frequent flyer points applied by the taxpayer to purchase air tickets to Chicago for medical treatment there constituted "an amount paid" for purposes of s. 118.2(2)(g). ...
Decision summary
Parkside Leasing Ltd. v. Smith, [1985] BTC 25 (HC) -- summary under Payment & Receipt
Smith, [1985] BTC 25 (HC)-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt receipt only when cheque deposited Interest paid by cheque was not received on the date that the cheque was received. ...
Old website (cra-arc.gc.ca)
T2 Corporation – Income Tax Guide – Chapter 5: Page 5 of the T2 return
T2 Corporation – Income Tax Guide – Chapter 5: Page 5 of the T2 return On this page... ... For details, see Line 628 – Additional deductions – credit unions. The reduction also does not apply to income earned from a personal service business or to a corporation that was, throughout the year, an investment corporation, a mortgage investment corporation, or a mutual fund corporation. ...
13 December 2013- 10:44am Angle Energy – Bellatrix merger contemplates unilateral s. 85 elections Email this Content Angle Energy shareholders have sold their share to Bellatrix for cash or Bellatrix shares (but with the overall cash/share split fixed at 22%/78%), followed by an amalgamation of Bellatrix, Angle and an Angle subsidiary (ARI). ... Summary of Joint Circular of Angle Energy and Bellatrix Exploration under Mergers & Acquisitions – Mergers – Shares for Shares or Cash. ...
News of Note post
Leggatt LJ stated: Counsel for Mr Jimenez … relied on a distinction … adopted … [by Rossiter CJ] in Oroville Reman & Reload … between documents of notice that merely involve the supply of information with no threat of penalties in the event of non-compliance and documents involving a compulsory process or containing a command. ... Such a measure does not involve the performance of any official act within the territory of another state – as would, for example, sending an officer of Revenue and Customs to enter the person's business premises in a foreign state and inspect business documents that are on the premises …. [T]he imposition of a civil penalty … for failure to comply with such a taxpayer notice would [not] involve an exercise of enforcement jurisdiction … provided that no steps are taken to seek to enforce the penalty in a foreign state. ...