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Decision summary
Capital City Savings & Credit Union Ltd. v. 299474 Alberta Ltd., [1990] 3 WWR 763 (Alta. Q.B.) -- summary under Retirement Savings Plan
Capital City Savings & Credit Union Ltd. v. 299474 Alberta Ltd., [1990] 3 WWR 763 (Alta. ...
FCTD (summary)
E.R. Squibb & Sons Ltd. v. MNR, 73 DTC 5139, [1973] CTC 120 (FCTD) -- summary under Income-Producing Purpose
Squibb & Sons Ltd. v. MNR, 73 DTC 5139, [1973] CTC 120 (FCTD)-- summary under Income-Producing Purpose Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Income-Producing Purpose In 1952, the taxpayer purchased 52 acres of land outside Montreal in order to construct its own facilities for use in research, manufacturing and marketing. ...
Decision summary
Levy v. Abercorris Slate & Slabe Co. (1887), 37 Ch. D. 260, [1886-90] All ER 509 -- summary under Investment Contract
Abercorris Slate & Slabe Co. (1887), 37 Ch. D. 260, [1886-90] All ER 509-- summary under Investment Contract Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(11)- Investment Contract Chitty J. stated (at Ch.D. p. 264): In my opinion a debenture means a document which either creates a debt or acknowledges it, and any document which fulfills either of these conditions is a "debenture. ...
FCA (summary)
Addison & Leyen Ltd. v. Canada, 2006 DTC 6248, 2006 FCA 107 -- summary under Perpetual Obligations
Addison & Leyen Ltd. v. Canada, 2006 DTC 6248, 2006 FCA 107-- summary under Perpetual Obligations Summary Under Tax Topics- Statutory Interpretation- Perpetual Obligations Sharlow J.A. stated (at p. 6260) that "it requires clear and explicit statutory language to deprive... a person of recourse to the minimal protection afforded by the right to seek judicial review of the exercise of the Minister's discretion" after expressing "considerable discomfort with the notion of a statutory obligation that may exist in perpetuity, subject only to the discretion of the Minister", which was the case with respect to assessments under s. 160 of the Act. ...
SCC (summary)
Furness, Withy & Company Limited v. Minister of National Revenue, 68 DTC 5033, [1968] CTC 35, [1968] SCR 221 -- summary under Article 8
Furness, Withy & Company Limited v. Minister of National Revenue, 68 DTC 5033, [1968] CTC 35, [1968] S.C.R. 221-- summary under Article 8 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 8 Article 5 of the Canada-U.K. ...
SCC (summary)
Stewart & Morrison Ltd. v. Minister of National Revenue, 72 DTC 6049, [1972] CTC 73, [1974] S.C.R. 477 -- summary under Capital Loss v. Loss
Stewart & Morrison Ltd. v. Minister of National Revenue, 72 DTC 6049, [1972] CTC 73, [1974] S.C.R. 477-- summary under Capital Loss v. ...
FCTD (summary)
The Queen v. Lagueux & Freres Inc., 74 DTC 6569, [1974] CTC 687 (FCTD) -- summary under Depreciable Property
Lagueux & Freres Inc., 74 DTC 6569, [1974] CTC 687 (FCTD)-- summary under Depreciable Property Summary Under Tax Topics- Income Tax Act- Section 13- Subsection 13(21)- Depreciable Property The taxpayer acquired machinery by having a rental company make the purchase and then entering into various leasing agreements with the rental company containing an option to purchase the equipment for $1, for 5% of a relatively minor amount otherwise owing under the lease or for the balance owing under the lease. ...
SCC (summary)
Minister of National Revenue v. Goldsmith Bros. Smelting & Refining Co., 54 DTC 1011, [1954] CTC 28, [1954] S.C.R. 55 -- summary under Legal and other Professional Fees
Smelting & Refining Co., 54 DTC 1011, [1954] CTC 28, [1954] S.C.R. 55-- summary under Legal and other Professional Fees Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Legal and other Professional Fees The taxpayer successfully defended charges under the Combines Investigation Act that it had combined with others to prevent or unduly lessen the competition in the commercial distribution of dental supplies. ...
FCA (summary)
Point Grey Golf & Country Club v. Canada, 2000 DTC 6217 (FCA) -- summary under Subsection 149(5)
Point Grey Golf & Country Club v. Canada, 2000 DTC 6217 (FCA)-- summary under Subsection 149(5) Summary Under Tax Topics- Income Tax Act- Section 149- Subsection 149(5) A golf club that qualified as a non-profit organization under s. 149(1)(l) was operating at a slight loss before it raised $4.2 million to help fund a building expansion. ...
TCC (summary)
Matt Harris & Son Ltd. v. The Queen, 2001 DTC 28 (TCC) (Informal Procedure) -- summary under Income-Producing Purpose
Matt Harris & Son Ltd. v. The Queen, 2001 DTC 28 (TCC) (Informal Procedure)-- 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 taxpayer, the operator of a wood contracting and construction business, was able to deduct the amount of racing expenses incurred by it (less prize money claimed) in respect of a stock car owned by it but driven by its sole shareholder and president, on the basis that such expenses were a form of advertising, and should not be disallowed simply because of the owner's satisfaction and interest in the activity. ...