Search - 哈尔滨到北京 公里数

The tax in question was imposed by Section 3 of The Excess Profits Tax Act, 1940, which read: 4 ‘ 3. ... By ‘‘clearly’’ he meant ‘ 4 fairly” or ‘‘accurately’’ or, to be more precise, “most nearly accurately’’. ...

At page 318 (D.T.C. 6164) of his judgment, Décary, J. stated: The question is whether the debts at issue were in fact acquired "... for the purpose of gaining or producing income from a business or property....” ...

The defendant argues (refer paragraph 18 of the statement of defence) that the golf course operation should be characterized as "an adventure in the nature of a trade” and that once that is done, then, generally accepted accounting principles should be applied to require the plaintiff to deduct all expenses incurred with respect to the venture as expenses for the year in which the property was disposed of ("the year in which the adventure was completed") — in this case 1979. ...

Fetterly of Calgary, "decided to do something" to protect their interests and engaged the Regina law firm of MacPher- son, Leslie & Tyerman. ...

Reliance is also placed upon the R & J Machine and Engineering Limited and The Queen, (unreported) Salhany, J., 1982. ...

This result is substantiated by the evidence of the Appellant and the documentation produced. d) & e) Cranbrook Condominiums and East Second Avenue [115] With respect to the Cranbrook Condominiums and the East Second Avenue property, counsel took the position that there were two issues. (1) Did the Appellant properly report the gains realized in these transactions when he filed his 1988 taxation return? ...

No goods shall be imported into Canada in any vehicle, ' other than a railway carriage, or on the person, between sunset and sunrise of any day, or at any time on a Sunday or a statutory holiday, except under a written permit from a collector, and under the supervision of an officer. ...

.: — This is an appeal by Cargill Limited from reassessments of tax in respect of its 1980 and 1981 taxation years. ...

. — rent, royalty or similar payment, including, butnotsoasto restrict the generality of the foregoing, any payment.... 3 The parties, through counsel, tendered an agreed statement of facts at trial (Exhibit 1). 4 Paragraph 883(a)(1) reads: (a) Income of foreign corporations from ships and aircraft.— The following items shall not be included in gross income of a foreign corporation, and shall be exempt from taxation under this subtitle: (I) Ships operated by certain foreign corporations.— Gross income derived by a corporation organized in a foreign country from the international operation of a ship or ships if such foreign country grants an equivalent exemption to corporations organized in the United States. 5 This “effective connection” is established by various factors, one of which, admittedly, is Norsk’s place of management. 6 Since this is a determination of foreign law, it is a finding of fact. ...

This case arises as a result of reassessment of the appellant (” Bronson") by the Minister, notices of reassessment which are dated February 13, 1984. ...