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FCTD
Arctic Offshore Marine Services Limited v. Her Majesty the Queen, the Minister of National Revenue,, [1986] 2 CTC 179
The season within which it can operate is short — the beginning of July to the end of September. ...
FCTD
Plastibeton Inc v. The Minister of National Revenue and the Attorney General of Canada, [1985] 1 CTC 319, 85 DTC 5240
The Court also referred to Denning, LJ, in Cardiff Rating Authority et al v Guest Keen Baldwins Iron & Steel Co, [1949] 1 All ER 27, who stated that one of the characteristics of a structure was that it was “intended to remain permanently on a permanent foundation”. ...
FCTD
Frederick G Vivian and Rex T Parsons v. Her Majesty the Queen, [1983] CTC 107, [1983] DTC 5144
I understand that to be the frequently cited opinion of Lord Diplock in Snook v London & West Riding Investments, [1967] 1 All ER 518: I apprehend that, if [sham] has any meaning in law, it means acts done or documents executed by the parties to the “sham” which are intended by them to give to third parties or to the court the appearance of creating between the parties legal rights and obliations different from the actual legal rights and obligations (if any) which the parties intend to create. ...
FCTD
Her Majesty the Queen v. Gordon a Bryce, [1980] CTC 401, 80 DTC 6304
The defendant, in 1975, paid the following: Mortgage $2,148.00 Taxes 655.99 Water & Sewer 151.50 Cablevision 59.40 $3,014.89 One-half of those amounts were paid for the benefit of the defendant’s former wife. ...
FCTD
Hirex Holdings Ltd. v. R., [1997] 1 CTC 103
They are: …] find as a fact that the accused Bruce Relkie was the “directing mind” of the company respecting the filing of refund applications, in accordance with the identification theory of liability set out by the Supreme court of Canada in Canadian Dredge and Dock Company Ltd. v. ...
FCTD
Grant Wilson v. Her Majesty the Queen, [1996] 3 CTC 203, 96 DTC 6452
.: — Grant Wilson (the “Taxpayer”) appeals a reassessment of his 1978 Income Tax Return on the basis that the Minister of National Revenue (“Revenue Canada”) failed to reassess with due dispatch following a notice of objection as required by subsection 165(3) of the Income Tax Act, S.C. 1970-71-72, c. 63 (the “Act”). ...
FCTD
William S. Hawkes, Appellant v. Her Majesty the Queen Respondent, [1997] 2 CTC 133, 97 DTC 5060
Procter & Gamble Co. (1985) 5 C.P.R.(3d) 417, 62 N.R. 364, at page 418 (N.R. 365) (F.C.A.). 2 [1996] 3 C.T.C. 74, (sub nom. ...
FCTD
Fuchs v. R., [1997] 2 CTC 246, 98 DTC 6560
Canada (Minister of Employment & Immigration). (1991), [1992] 1 F.C. 133 (Fed. ...
FCTD
Garage Montplaisir Ltée v. Minister of National Revenue, [1998] 1 CTC 51, 96 DTC 6557
Pinard & Pinard (1974) Ltée (hereinafter “Pinard Ltée”) was founded in 1927. ...
FCTD
Gadbois v. Transport H. Cordeau Inc., [1998] 3 CTC 68
., granted advances totalling some $63,000 to Cordeau between February and May 1996. (...)? ...