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FCA
Whissell v. Canada (Attorney General), 2016 FCA 254
GLEASON J.A. BETWEEN: JOHN WHISSELL Appellant and HER MAJESTY THE QUEEN Respondent Heard at Edmonton, Alberta, on October 18, 2016. ... GLEASON J.A. [1] The appellant appeals from two judgments of the Tax Court rendered on November 21, 2014. ... Pentney Deputy Attorney General of Canada Edmonton, Alberta FOR THE RESPONDENT ...
FCA
Canada (Attorney General) v. Fink, 2017 FCA 87
DE MONTIGNY J.A. BETWEEN: ATTORNEY GENERAL OF CANADA Appellant and RON FINK Respondent Heard at Edmonton, Alberta, on April 25, 2017. ... NEAR J.A. Date: 20170427 Docket: A-276-16 Citation: 2017 FCA 87 CORAM: STRATAS J.A. ... RON FINK PLACE OF HEARING: Edmonton, Alberta DATE OF HEARING: April 25, 2017 REASONS FOR JUDGMENT BY: DE MONTIGNY J.A. ...
FCA
Brightline Foundation v. Canada (National Revenue), 2023 FCA 23
REASONS FOR ORDER BY: WEBB J.A. Date: 20230202 Docket: A-212-22 Citation: 2023 FCA 23 Present: WEBB J.A. ... However, this argument is not supported by the wording of paragraph 168(2)(b) of the Act: … the Minister may, after the expiration of 30 days from the day of mailing of the notice, or after the expiration of such extended period from the day of mailing of the notice as the Federal Court of Appeal or a judge of that Court, on application made at any time before the determination of any appeal pursuant to subsection 172(3) from the giving of the notice, may fix or allow, publish a copy of the notice in the Canada Gazette, … [10] Paragraph 168(2)(b) of the Act merely allows this Court (as a result of an application brought by a registered charity under this paragraph) to fix or allow a longer period of time before a copy of the notice sent to the registered charity under subsection 168(1) of the Act could be published in the Canada Gazette. ... François Daigle Deputy Attorney General of Canada For The Respondent ...
FCA
Barnabe Estate v. Minister of National Revenue, 99 DTC 5387, [1999] 4 CTC 5 (FCA)
Barnabe was to transfer the assets-- Q And had- A — and Mr. Barnabe said yes. ... Mitsui & Co. (Canada) falls into this second category. In Mitsui & Co. ... Barnabe was to transfer the assets — Q And had — A — and Mr. Barnabe said yes. ...
FCA
Minister of National Revenue v. Cassidy Limitée, Faema Distributeur Inc. And Russell Food Equipment Limited, [1994] 2 CTC 108
(Customs & Excise), [1984] C.T.C. 75, 84 D.T.C. 6081 (F.C.A.) is authoritative on this point at pages 79-80 (D.T.C. 6084-85): It appears to me that the expressions "manufacturer or producer”, “manufactured or produced” and “manufacture or production”, which are found in various places and contexts in the Act, are used for differing purposes and that it is wrong to try to interpret one by reference to what another means or has been held to include either in a particular context or in general. ... (Customs & Excise) (1983), 18 Ex. C.R. 31, [1983] C.T.C. 416, at page 33 (C.T.C. 418), stated: The ordinary and accepted meaning of the word "marchandises" (goods) is that of items circulated on the commercial market, items intended for sale. ...
FCA
Jewish National Fund of Canada Inc. v. Canada (National Revenue), 2025 FCA 114
REASONS FOR ORDER BY: WALKER J.A. Date: 20250610 Docket: A-245-24 Citation: 2025 FCA 114 Present: WALKER J.A. ... DATED: juNE 10, 2025 WRITTEN REPRESENTATIONS BY: Andrew Brodkin Nando De Luca For The Appellant Adam Aptowitzer Lisa Watzinger For The Appellant Linsey Rains Alex Nguyen Mengjiao Liu For The Respondent SOLICITORS OF RECORD: GOODMANS LLP Toronto, Ontario For The Appellant KPMG Law LLP Toronto, Ontario For The Appellant Shalene Curtis-Micallef Deputy Attorney General of Canada For The Respondent ...
FCA
The Queen v. Cival, 83 DTC 5168, [1983] CTC 153 (FCA)
Do they — meaning your employer — come around and present you with this document? ... I mean, we have a description on the top, Headquarters Area, April 1/79 — to March 31, 1980. ... Now to your knowledge and your experience, can the use of a personal car — if I may say so — be forced upon an employee? ...
FCA
Fortius Foundation v. Canada (National Revenue), 2022 FCA 176
MINISTER OF NATIONAL REVENUE MOTION DEALT WITH IN WRITING WITHOUT APPEARANCE OF PARTIES DATED: October 19, 2022 WRITTEN REPRESENTATIONS BY: Greg J. Allen For The Applicant Lynn Burch Selena Sit Yianni Pappas-Acreman For The Respondent SOLICITORS OF RECORD: Allen / McMillan Litigation Counsel Vancouver, British Columbia For The Applicant A. François Daigle Deputy Attorney General of Canada For The Respondent ...
FCA
Agt Ltd. v. Canada (Attorney General), 97 DTC 5189, [1997] 2 CTC 275 (F.C.T.A.)
Canada (Director of Investigation & Research) (Director of Investigation & Research, Restrictive Trade Practices Commission) 67 D.L.R. (4th) 161 at 234 (S.C.C.). 19 See La Forest J. in Thomson Newspapers Ltd. v. Canada (Director of Investigation & Research) (Director of Investigation & Research, Restrictive Trade Practices Commission) (1990), 67 D.L.R. (4th) 161 at 234 (S.C.C.). 20 See La Forest J. in Thomson Newspapers Ltd. v. Canada (Director of Investigation & Research) (Director of Investigation & Research, Restrictive Trade Practices Commission) 67 D.L.R. (4th) 161 at 209 (S.C.C.). 21 7?. ...
FCA
Roney (C.H.) v. M.N.R., [1991] 1 CTC 280
He was also, since 1962, vice- president of Universal Alarms Ltd (“ Universal Alarms") of which he held 50 per cent of the shares. ... Wednesdays, in full, and the evenings of other days, he was on the properties, checking the cattle in the fields, the fencing, and ” going over the general operation with the farm manager". ... Whether a source of income is a taxpayer's “ chief source" of income is both a relative and objective test. ...