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FCA
Bonnybrook Industrial Park Development Co. Ltd. v. Canada (National Revenue), 2018 FCA 136
WOODS J.A. BETWEEN: BONNYBROOK PARK INDUSTRIAL DEVELOPMENT CO. LTD. ... MINISTER OF NATIONAL REVENUE PLACE OF HEARING: Toronto, Ontario DATE OF HEARING: JANUARY 9, 2018 REASONS FOR JUDGMENT BY: WOODS J.A. CONCURRED IN BY: NEAR J.A. DISSENTING REASONS BY: STRATAS J.A. DATED: July 18, 2018 APPEARANCES: Justin Kutyan Thang Trieu For The Appellant Craig Maw Nancy Arnold For The Respondent SOLICITORS OF RECORD: KPMG Law LLP Toronto, Ontario For The Appellant Nathalie G. ...
FCA
Canada v. Bowker, 2023 FCA 133
MARGO DIANNE BOWKER PLACE OF HEARING: Vancouver, British Columbia DATE OF HEARING: March 29, 2023 REASONS FOR JUDGMENT BY: PELLETIER J.A. ... GLEASON J.A. DATED: June 8, 2023 APPEARANCES: Laura Zumpano Natasha Tso For The Appellant Alistair G. Campbell For The Respondent SOLICITORS OF RECORD: Shalene Curtis-Micallef Deputy Attorney General of Canada For The Appellant Legacy Tax + Trust Lawyers Vancouver, British Columbia For The Respondent ...
FCA
Canada v. Paletta, 2022 FCA 86
THE ESTATE OF PASQUALE PALETTA PLACE OF HEARING: TORONTO, ONTARIO DATE OF HEARING: APRIL 4, 2022 REASONS FOR JUDGMENT BY: NOËL C.J. ... LASKIN J.A. DATED: May 17, 2022 APPEARANCES: Justice Malone Dina Elleithy For The Appellant Justin Kutyan Kelly Ng For The Respondent SOLICITORS OF RECORD: A. François Daigle Deputy Attorney General of Canada Ottawa, Ontario For The Appellant KPMG Law LLP Barristers and Solicitors Toronto, Ontario For The Respondent ...
FCA
Galati v. Harper, 2016 FCA 39
II. THE DECISION UNDER APPEAL [14] In its decision, the Federal Court noted that Mr. ... III. ISSUES [16] Mr. Galati and the CRC raise two issues. ... DATED: february 8, 2016 APPEARANCES: Rocco Galati For The Appellant, ROCCO GALATI Paul Slansky For The Appellant, CONSTITUTIONAL RIGHTS CENTRE INC. ...
FCA
Intermodal Container Transport Ltée v. Beauchamp, docket ITA-1716-98
Beauchamp, docket ITA-1716-98 Date: 1999 Docket: IT A-1716-98 MONTRÉAL, QUEBEC, THE DAY OF , 1999 Present: Mr. ... This order applies to and will be placed in file IT A-9734-98. ... I. Instalment sale of property [10] An initial series of contracts involves seized property number 9: 1 green truck with rotary flange, NS/FCIN3012RW33493. [11] This property is alleged to be the Beauchamps' by the following reasoning. [12] It was allegedly assigned to the Beauchamps by Beau-Co Corporation Inc. ...
FCA
Ghali v. Canada, 2005 DTC 5472, 2004 FCA 60
Date: 20040212 Docket: A-488-01 Citation: 2004 FCA 60 CORAM: DÉCARY J.A. ... CONCURRING: DÉCARY J.A. ... THE QUEEN PLACE OF HEARING: Montréal, Quebec DATE OF HEARING: September 18, 2003 REASONS FOR JUDGMENT: NADON, J.A. ...
FCA
Squamish Indian Band v. Canada (Fisheries and Oceans), 2019 FCA 216
MINISTER OF FISHERIES AND OCEANS PLACE OF HEARING: Vancouver, British Columbia DATE OF HEARING: April 8, 2019 REASONS FOR JUDGMENT BY: DAWSON J.A. ... RIVOALEN J.A. DATED: AUGUST 8, 2019 APPEARANCES: F. Matthew Kirchner Lisa Glowacki For The Appellants Mara Tessier Monika Bittel For The Respondent SOLICITORS OF RECORD: Ratcliff & Company LLP North Vancouver, British Columbia For The Appellants Nathalie G. Drouin Deputy Attorney General of Canada For The Respondent ...
FCA
De Geest v. Canada, 2022 FCA 22
MONAGHAN J.A. Date: 20220207 Docket: A-101-19 Citation: 2022 FCA 22 CORAM: WEBB J.A. ... In reassessing the appellant, the Minister allowed the following amounts as business expenses and reassessed the appellant based on the following amounts of net income/profit: Year Amount Received Expenses Allowed Net Income/Profit 2009 $246,920 $68,646 =B2-C2 $178,274 2010 $247,264 $50,773 =B3-C3 $196,491 2011 $371,962 $121,570 =B4-C4 $250,392 Total: =SUM(ABOVE) $625,157 [5] Although the difference between the unreported revenue ($247,264) and the expenses allowed ($50,773) for 2010 is $196,491, the Tax Court Judge referred to $196,490 as the unreported net income for 2010. ... François Daigle Deputy Attorney General of Canada For The Respondent ...
FCA
High-Crest Enterprises Limited v. Canada, 2017 FCA 88
II. Procedural Background [9] The matter was heard on February 26, 2014 by a judge of the Tax Court. ... B. Discretion [85] Assuming the Chief Justice has a power to reassign, he is not forced to exercise it. ... Pentney Deputy Attorney General of Canada For The Respondent ...
FCA
Elm Ridge Country Club Inc. v. Minister of National Revenue, [1999] 3 CTC 163
Ratti write at p. 6-1 that “income from property” means [TRANSLATION] [...] the return on invested capital when neither the taxpayer entitled to it nor any of its agents has devoted much effort, time or attention to generating the income [...] ... There are two important exceptions to this principle [...] One arises where the securities held constitute an integral part of the taxpayer’s other business activities; the other, where the taxpayer’s investment activities are such that they amount in themselves to the conduct of a separate business [...] ... This presumption is very far-reaching [...] The legislature is presumed to have a mastery of existing law, both common law and statute law. as well as the case law interpreting statutes. ...