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TCC

Placements T.S. Inc. v. The Queen, 94 DTC 1302, [1994] 1 CTC 2464 (TCC)

What is “reasonable” is not the subjective view of either the respondent or appellant but the view of an objective observerwith a knowledge of all the pertinent facts: Canadian Propane Gas & Oil Ltd. v. ...
FCA

Robertson v. The Queen, 90 DTC 6070, [1990] 1 CTC 114 (FCA)

.] per Lord Diplock, at page 326 The Abbot v. Philbin judgment was in no way put in question. ...
FCTD

Yarmouth Industrial Leasing Ltd. v. The Queen, 85 DTC 5401, [1985] 2 CTC 67 (FCTD)

The process so far as then s 39 of the Income Tax Act was concerned was completed by Cattanach J in Vineland Quarries & Crushed Stone Ltd v Minister of National Revenue, [1966] CTC 69; 66 DTC 5092: “In my view the word 'controlled' in section 39(4)(b) contemplates and includes such a relationship as, in fact, brings about a control by virtue of majority voting power, no matter how that result is effected, that is, either directly or indirectly.” ...
FCTD

Gray v. The Queen, 86 DTC 6504, [1986] 2 CTC 382 (FCTD)

The evidence is clear that the plaintiff did not extricate himself from the auto repair business in either 1978 or 1983, in part, because he could not afford to do so the money made from employment in those businesses was being used by him to help establish his farm. ...
FCA

R. v. Donnelly, 97 DTC 5499, [1998] 1 CTC 23 (FCA)

The second method of distinguishing Graham is the classical one on the facts. ...
FCTD

Midyette v. The Queen, 85 DTC 5565, [1985] 2 CTC 362 (FCTD)

The bulk of judicial prose generated on the subject of fiscal residence has related to the peripatetic lifestyle of the leisurely wealthy the jet setters of yesteryear. ...
FCTD

Hart v. The Queen, 86 DTC 6335, [1986] 2 CTC 63 (FCTD)

Greenbaum (1957), 55 L.G.R. 129, he quotes: Anybody can apply for it a member of the public who has been inconvenienced, or a particular party or person who has a particular grievance of his own. ...
TCC

Miramar Shoe Imports Limited v. Minister of National Revenue, 91 DTC 317, [1991] 1 CTC 2124 (TCC)

Nevill & Co. Ltd. v. Federal Commissioner of Taxation a lump sum paid to get rid of an unnecessary director was held to be a revenue payment since •The purpose was transient and, although not itself recurrent, it was connected with the ever-recurring question of personnel" (per Dixon, J.). ...
TCC

533702 Ontario Ltd. v. MNR, 91 DTC 982, [1991] 2 CTC 2102 (TCC)

The only business name displayed on the premises at 833 Central Avenue was the name "Brouwer Plumbing & Heating". ...
TCC

Brock v. MNR, 91 DTC 1079, [1991] 2 CTC 2121 (TCC)

McAlpine, Roberts & Company, 37 B.C.L.R. 332. 5 Section 2. 6 In the matter of the Solicitors Act: and in the matter of Lang, Michener, Cranson, Farquharson and Wright, and Eileen Newell, Ont. ...

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