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EC summary

Blauer v. MNR, 71 DTC 5113, [1971] CTC 154 (F.C.T.A.), briefly aff'd 75 DTC 5076, [1975] CTC 112 (SCC) -- summary under Payment & Receipt

.), briefly aff'd 75 DTC 5076, [1975] CTC 112 (SCC)-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt post-dated cheque A post-dated cheque was payable for purposes of ss. 12(1)(l) and 76(1) on its date rather than the date of delivery. ...
Decision summary

Narich Pty. Ltd. v. Commissioner of Pay-roll Tax, [1984] BTC 8019 (PC) -- summary under Payment & Receipt

Commissioner of Pay-roll Tax, [1984] BTC 8019 (PC)-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt indirect receipt of wages An argument was rejected to the effect that fees received by employees of a company were not wages because they were collected directly from clients of the company. ...
FCTD (summary)

Western Union Insurance Co. v. The Queen, 83 DTC 5388, [1983] CTC 363 (FCTD) -- summary under Payment & Receipt

The Queen, 83 DTC 5388, [1983] CTC 363 (FCTD)-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt sending of cheque to sender's lawyers The sending of a cheque by the lender to (its) solicitors did not constitute the payment of a sum to the borrower. ...
TCC (summary)

Transalta Corporation v. The Queen, 2012 DTC 1106 [at at 3044], 2012 TCC 86 -- summary under Payment & Receipt

The Queen, 2012 DTC 1106 [at at 3044], 2012 TCC 86-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt past services Margeson J. accepted (at para. 99) that employees to whom the taxpayer issued shares in payment of bonuses to them gave consideration equal to the full value of those share "on the basis of past unremunerated services rendered to the Appellant. ...
FCTD (summary)

The Queen v. Ans, 83 DTC 5038, [1983] CTC 8 (FCTD) -- summary under Payment & Receipt

Ans, 83 DTC 5038, [1983] CTC 8 (FCTD)-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt receipt by set-off A company's shareholder was held to have received a bonus when the amount of the bonus payable by the company was credited against the balance outstanding on the loan by the company to the shareholder. ...
TCC (summary)

Johnson v. The Queen, 2010 DTC 1213 [at at 3568], 2010 TCC 321 (Informal Procedure) -- summary under Payment & Receipt

The Queen, 2010 DTC 1213 [at at 3568], 2010 TCC 321 (Informal Procedure)-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt frequent flyer points Frequent flyer points applied by the taxpayer to purchase air tickets to Chicago for medical treatment there constituted "an amount paid" for purposes of s. 118.2(2)(g). ...
Decision summary

Parkside Leasing Ltd. v. Smith, [1985] BTC 25 (HC) -- summary under Payment & Receipt

Smith, [1985] BTC 25 (HC)-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt receipt only when cheque deposited Interest paid by cheque was not received on the date that the cheque was received. ...
Decision summary

Minsham Properties Ltd. v. Price, [1990] BTC 528 (Ch. D.) -- summary under Payment & Receipt

.)-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt mere addition of accrued interest not payment Although "there can be no doubt that a book entry can constitute payment" (p. 540), in the case of an informal loan from the taxpayer's parent corporation to the taxpayer, the mere addition of accrued interest to the principal owing by the taxpayer to the parent did not constitute payment. ...
EC summary

Robwaral Ltd. v. MNR, 60 DTC 1025, [1960] CTC 16 (Ex Ct), briefly aff'd 64 DTC 5266 (SCC) -- summary under Payment & Receipt

MNR, 60 DTC 1025, [1960] CTC 16 (Ex Ct), briefly aff'd 64 DTC 5266 (SCC)-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt dividend not received until cheque received A dividend was "received" by a shareholder in the year in which the cheque was drawn and received by him, rather than in the previous year in which the dividend was declared and in which the record date occurred. ...
Decision summary

Downtown King West Development Corp. v. Massey Ferguson Industries Ltd. (1993), 14 OR (3d) 528 (Ont Ct GD) -- summary under Rectification & Rescission

Massey Ferguson Industries Ltd. (1993), 14 OR (3d) 528 (Ont Ct GD)-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission Given that a lease as signed did not reflect the terms agreed to in the letter of intent and that a change to the terms of a right of first refusal was never discussed with the party whom such change might adversely affect, this was found to be an appropriate case for rectification. ...

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