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TCC (summary)

Restaurant Loupy's inc. v. The Queen, 2016 TCC 260 (Informal Procedure) -- summary under Registrant

The Queen, 2016 TCC 260 (Informal Procedure)-- summary under Registrant Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Registrant registrant based on wind-up activities Favreau J found that, notwithstanding the revocation of its revocation, the taxpayer was still a “registrant” whose definition includes a “person who is required to be registered”- given that it still held equipment which it was seeking to sell (some of which it sold eight months’ later). ...
TCC (summary)

JDI 2000 Transport Ltd. v. The Queen, 2010 DTC 1206 [at at 3541], 2010 TCC 310 -- summary under Subsection 163(2)

The Queen, 2010 DTC 1206 [at at 3541], 2010 TCC 310-- summary under Subsection 163(2) Summary Under Tax Topics- Income Tax Act- Section 163- Subsection 163(2) sloppy bookkeeping gross negligence In finding that the portion of penalties assessed against the taxpayer that were based on related company expenses should be reversed, Woods, J. stated (at para. 42) that: It is quite possible that these errors were a matter of sloppy bookkeeping. ...
TCC (summary)

Van Leenen v. MNR, 91 DTC 1265, [1991] 2 CTC 2442 (TCC) -- summary under Subsection 152(1)

MNR, 91 DTC 1265, [1991] 2 CTC 2442 (TCC)-- summary under Subsection 152(1) Summary Under Tax Topics- Income Tax Act- Section 152- Subsection 152(1) In dealing with a submission that a Revenue Canada official had given the taxpayer some assurance that the taxpayer would not be assessed under s. 227.1, Mogan J. stated (p. 1270): "... ...
TCC (summary)

Fortino v. R., 97 DTC 55, [1997] 2 CTC 2184 (TCC), briefly aff'd on procedural grounds 2000 DTC 6060 (FCA) -- summary under Subsection 163(2)

., 97 DTC 55, [1997] 2 CTC 2184 (TCC), briefly aff'd on procedural grounds 2000 DTC 6060 (FCA)-- summary under Subsection 163(2) Summary Under Tax Topics- Income Tax Act- Section 163- Subsection 163(2) In finding that even if (contrary to her actual finding) that amounts received for non-compete covenants by the taxpayer were taxable, penalties would not have been applicable, Lamarre TCJ. stated (at p. 72): "... considering all the different positions taken by the Minister to try to justify his own assessments, I do not see how we can attribute to the appellants a degree of negligence... when especially they have obtained professional advice that the NCA payments were not taxable. ...
TCC (summary)

Taylor v. The Queen, 2014 DTC 1108 [at at 3229], 2014 TCC 102 (Informal Procedure) -- summary under Pension Income

The Queen, 2014 DTC 1108 [at at 3229], 2014 TCC 102 (Informal Procedure)-- summary under Pension Income Summary Under Tax Topics- Income Tax Act- Section 118- Subsection 118(7)- Pension Income periodic discretionary withdrawals periodic amount The taxpayer had discretion as to when and in what amount to withdraw from her RRSP. ...
TCC (summary)

Taylor v. The Queen, 2014 DTC 1108 [at at 3229], 2014 TCC 102 (Informal Procedure) -- summary under Annuity

The Queen, 2014 DTC 1108 [at at 3229], 2014 TCC 102 (Informal Procedure)-- summary under Annuity Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Annuity periodic discretionary withdrawals periodic amount The taxpayer had discretion as to when and in what amount to withdraw from her RRSP. ...
TCC (summary)

Ruff v. The Queen, 2012 TCC 105 -- summary under Section 3

The Queen, 2012 TCC 105-- summary under Section 3 Summary Under Tax Topics- Income Tax Act- Section 3 The taxpayer, a lawyer, was bilked of $400,000 by scam artists, posing as clients, who induced him to incur "processing " fees in connection with the recovery of a supposed container in the Ivory Coast containing US$8.5 million of cash. ...
TCC (summary)

Ruff v. The Queen, 2012 TCC 105 -- summary under Paragraph 4(1)(a)

The Queen, 2012 TCC 105-- summary under Paragraph 4(1)(a) Summary Under Tax Topics- Income Tax Act- Section 4- Subsection 4(1)- Paragraph 4(1)(a) The taxpayer, a lawyer, was bilked of $400,000 by scam artists, posing as clients, who induced him to incur "processing " fees in connection with the recovery of a supposed container in the Ivory Coast containing US$8.5 million of cash. ...
TCC (summary)

Ruff v. The Queen, 2012 TCC 105 -- summary under Section 67

The Queen, 2012 TCC 105-- summary under Section 67 Summary Under Tax Topics- Income Tax Act- Section 67 The taxpayer, a lawyer, was bilked of $400,000 by scam artists, posing as clients, who induced him to pay for "processing " fees in connection with the recovery of a supposed container in the Ivory Coast containing US$8.5 million of cash. ...
TCC (summary)

Armada Equipment Corporation v. The Queen, 2007 DTC 879, 2007 TCC 260 (Informal Procedure) -- summary under Subsection 2900(2)

The amount paid to Deacur & Co. was a consequence of research and development which would already taken place. ...

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