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SCC (summary)

Eli Lilly & Co. v. Novopharm Ltd. (1998), 161 DLR (4th) 1, [1998] 2 SCR 129 -- summary under Tax Avoidance

Eli Lilly & Co. v. Novopharm Ltd. (1998), 161 DLR (4th) 1, [1998] 2 S.C.R. 129-- summary under Tax Avoidance Summary Under Tax Topics- General Concepts- Tax Avoidance In discussing E.I. De Pont De Nemours & Co. v. Shell Oil Co., 227 U.S.P.Q. 223 (1985), Iacobucci J. stated (at p. 34) that in that case: "the unlicensed party actually manufactured the licensed article allegedly as the agent of the licensee, only then to 'purchase' the article from the licensee immediately upon its manufacture. ...
SCC (summary)

Will-Kare Paving & Contracting Ltd. v. Canada, 2000 DTC 6467, 2000 SCC 36, [2000] 1 SCR 915 (SCC) -- summary under Hansard, explanatory notes, etc.

Will-Kare Paving & Contracting Ltd. v. Canada, 2000 DTC 6467, 2000 SCC 36, [2000] 1 S.C.R. 915 (SCC)-- summary under Hansard, explanatory notes, etc. ...
SCC (summary)

James Richardson & Sons v. M.N.R., 84 DTC 6325, [1984] CTC 345, [1984] 1 SCR 614 -- summary under Specific v. General Provisions

James Richardson & Sons v. M.N.R., 84 DTC 6325, [1984] CTC 345, [1984] 1 S.C.R. 614-- summary under Specific v. ...
SCC (summary)

International Power Co. v. McMaster University / In re Porto Rico Power Co., [1946] SCR 178, [1946] 2 DLR 81 -- summary under Investment Contract

McMaster University / In re Porto Rico Power Co., [1946] S.C.R. 178, [1946] 2 DLR 81-- summary under Investment Contract Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(11)- Investment Contract Accrued but unpaid dividends were not a debt because there was no guarantee of payment. ...
SCC (summary)

James Richardson & Sons v. M.N.R., 84 DTC 6325, [1984] CTC 345, [1984] 1 SCR 614 -- summary under Paragraph 221(1)(d)

James Richardson & Sons v. M.N.R., 84 DTC 6325, [1984] CTC 345, [1984] 1 S.C.R. 614-- summary under Paragraph 221(1)(d) Summary Under Tax Topics- Income Tax Act- Section 221- Subsection 221(1)- Paragraph 221(1)(d) It was stated that if the Minister thinks that traders in the commodities futures market generally are not reporting their transactions properly for income tax purposes, then he can obtain a regulation under S.221(1)(d) requiring all such traders to file returns of their transactions, rather than making an impermissible demand for information under S.231(3). ...
SCC (summary)

Mitsui & Co. (Canada) Ltd. v. Royal Bank of Canada, [1995] 2 SCR 187 -- summary under Subsection 49(1)

Mitsui & Co. (Canada) Ltd. v. Royal Bank of Canada, [1995] 2 S.C.R. 187-- summary under Subsection 49(1) Summary Under Tax Topics- Income Tax Act- Section 49- Subsection 49(1) Before finding that a clause in a lease giving the lessee the unilateral right to compel the lessor to sell helicopters to the lessee at their reasonable fair market value was an "option", Major J. stated his agreement with the following list of the three principal features of an option: exclusivity and irrevocability of the offer to sell within the time period specified in the option; specification of how the contract of sale may be created by the optionholder; and obligation of the parties to enter into a contract of sale if the option is exercised. ...
SCC (summary)

Osler, Hammond & Nanton Limited v. Minister of National Revenue, 63 DTC 1119, [1963] CTC 164, [1963] S.C.R. 432 -- summary under Shares

Osler, Hammond & Nanton Limited v. Minister of National Revenue, 63 DTC 1119, [1963] CTC 164, [1963] S.C.R. 432-- summary under Shares Summary Under Tax Topics- Income Tax Act- Section 9- Capital Gain vs. ...
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. ...
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. ...

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