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Decision summary
Agence du revenu du Québec v. 9141-5315 Québec Inc., 2017 QCCQ 12233 -- summary under Subsection 223(2)
[A] document … had to be signed by each of the employees, confirming that they were familiar with the obligation…. ...
TCC (summary)
Lavrinenko v. The Queen, 2017 TCC 230 (Informal Procedure), aff'd 2019 FCA 51 -- summary under Shared-Custody Parent
. … The contrary conclusion would strain the ordinary meaning of the words “equal or near equal”. ...
TCC (summary)
Birchcliff Energy Ltd. v. The Queen, 2017 TCC 234 -- summary under Subsection 245(3)
. … I have no hesitation in concluding that the benefit sought by Birchcliff from the amalgamation was to obtain the tax attributes, the losses, of Veracel. ...
Decision summary
SAE Education Ltd v. Revenue and Customs Commissioners, [2017] EWCA Civ 1116 -- summary under University
Before going on to find that SEL did not qualify as a “college…of…a university” for UK VAT purposes, Patten LJ stated (at paras 64-65): The word "college" … denotes a group of people organised as an institution usually (but not necessarily) in the field of education. ...
Decision summary
6305521 Canada Inc. v. ARQ, 2017 QCCQ 14869 -- summary under Personal Services Business
. … It is customary that the required work is subject to detailed quotations which provided a template for detailed steps to be performed. ...
FCA (summary)
Iggillis Holdings Inc. v. Canada (National Revenue), 2018 FCA 51 -- summary under Solicitor-Client Privilege
In my view, in the circumstances of this case, [the appellants] had sufficient common interest in the transactions to warrant a finding that, in Alberta or British Columbia, the … memo is protected from disclosure by solicitor-client privilege. ...
TCC (summary)
Custodio v. The Queen, 2018 TCC 47 -- summary under Paragraph 227.1(2)(a)
. … [T]he respondent was required to demonstrate, on a preponderance of evidence, not only that a certificate specifying the amount for which the corporation was liable had been registered in the Federal Court, but also that that amount had been returned unsatisfied in whole or in part. ...
FCTD (summary)
Canada (Attorney General) v. Chad, 2018 FC 319 -- summary under Paragraph 2(b)
In any constitutional climate, the administration of justice thrives on exposure to light — and withers under a cloud of secrecy. 2. ...
Decision summary
NWorks Management Corp. (Globotech Communications) v. Lincourt, 2018 QCCQ 1021 -- summary under Subsection 223(1)
. … [T]he object of ETA section 223 and QSTA section 425 is to permit the recipient from whom the taxes are collected to be apprised of the amounts owing for the supply and what are the payments due for each of the taxes so as permit it to receive credits to which it has a right upon being invoiced for those taxes. ...
FCA (summary)
Fiducie financière Satoma v. Canada, 2018 FCA 74 -- summary under Tax Benefit
Canada, 2018 FCA 74-- summary under Tax Benefit Summary Under Tax Topics- Income Tax Act- Section 245- Subsection 245(1)- Tax Benefit tax benefit to trust from tax-free dividend even though not distributed to a beneficiary In order to strip surplus of an operating corporation (“Gennium”) controlled by the Pilon family, a dividend paid by Gennium was distributed through a series of transactions to a corporation with no assets (“9163”), which then paid the amount to a Pilon family trust (“Satoma Trust” – which also had a corporate beneficiary) as a dividend on special shares that Satoma Trust held in 9163. ...