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TCC
Yao v. The King, 2024 TCC 19 (Informal Procedure)
COMMON REASONS FOR JUDGMENT TABLE OF CONTENTS TOC \o "1-5" \u I. ... [32] In May 2017, Ms. Zhang claimed refugee protection under the IRPA. ... Bocock DATE OF JUDGMENT: February 15, 2024 APPEARANCES: Co-Counsel for the Appellant: Alexander Cobb Andrew Boyd Graeme Rotrand Ada Chan Jackie Chiu Counsel for the Respondent: Arnold Bornstein Alexander Hinds Laoura Christodoulides Counsel for the Intervenor Nabila Qureshi Adrian Merdzan Anu Bakshi COUNSEL OF RECORD: For the Appellant: Alexander Cobb Andrew Boyd Graeme Rotrand Firm: Osler Hoskin & Harcourt LLP Ada Chan Jacky Chiu Firm: Chinese and Southeast Asian Legal Clinic For the Respondent: Shalene Curtis-Micallef Deputy Attorney General of Canada Ottawa, Canada For the Intervenor: Adrian Merdzan Nabila F. ...
TCC
Rowe v. The Queen, 2017 TCC 122
Lewis “ with all [his] heart, ” he had been “ misled.” [24] During his oral testimony, Mr. ... Sommerfeldt DATE OF JUDGMENT: June 23, 2017 APPEARANCES: For the Appellant: The Appellant himself Counsel for the Respondent: Christian Cheong COUNSEL OF RECORD: For the Appellant: Name: Firm: For the Respondent: William F. Pentney Deputy Attorney General of Canada Ottawa, Canada [1] Income Tax Act, RSC 1985, c.1 (5th Supplement), as amended. [2] Mr. ...
TCC
Nadeau v. The Queen, docket 97-3019-IT-I (Informal Procedure)
the Class C shares: (I) were non-voting shares; (II) were retractable at the market value received by the company in consideration of their issue; and (III) carried the right to a cumulative 10% dividend calculated based on the redemption price, and this right was held in preference to the Class A, B and D shares; and viii. ... & C. Nadeau Ltée; · the appellant would pay a minimum of tax as a result of the transfer of her shares; and · the appellant and her son Claude would benefit from the capital gains exemption. [18] These instructions required painstaking, complex work. ... & C. Nadeau Ltée, have a bona fide purpose? What was its purpose? ...
TCC
Groves v. The Queen, 2017 TCC 66 (Informal Procedure)
Hogan” Hogan J. Citation: 2017 TCC 66 Date: 20170504 Docket: 2016-4033(IT)I BETWEEN: TINA GROVES, Appellant, and HER MAJESTY THE QUEEN, Respondent. ... Hogan DATE OF JUDGMENT: May 4, 2017 APPEARANCES: For the Appellant: The Appellant herself Counsel for the Respondent: Bhuvana Sankaranarayanan COUNSEL OF RECORD: For the Appellant: Name: Firm: For the Respondent: William F. Pentney Deputy Attorney General of Canada Ottawa, Canada [1] RSC 1985, c 1 (5th Supp). [2] NTD: Ms. ...
TCC
Netten v. M.N.R., 2017 TCC 8
., 2017 TCC 8 Docket: 2016-1539(CPP) BETWEEN: SHIRLEY NETTEN, Appellant, and THE MINISTER OF NATIONAL REVENUE, Respondent. ... THE MINISTER OF NATIONAL REVENUE PLACE OF HEARING: Ottawa, Ontario DATE OF HEARING: November 17, 2016 REASONS FOR JUDGMENT BY: The Honourable Lucie Lamarre, Associate Chief Justice DATE OF JUDGMENT: February 3, 2017 APPEARANCES: For the Appellant: The Appellant herself Counsel for the Respondent: Vincent Bourgeois COUNSEL OF RECORD: For the Appellant: Name: Firm: For the Respondent: William F. ... The Queen, 2004 FCA 403. [23] 2004 FCA 327. [24] 2015 FCA 94, [2015] F.C.J. ...
TCC
Abrametz v. The Queen, 2014 TCC 227
Graham Participants: For the Appellant: The Appellant Himself Counsel for the Respondent: Ainslie Schroeder ORDER Paragraphs 8, 9, 13(i), 13(iv), 14, 16 and 17 of the Notice of Appeal are hereby struck. ... Graham DATE OF ORDER: July 17, 2014 PARTICIPANTS: For the Appellant: The Appellant Himself Counsel for the Respondent: Ainslie Schroeder COUNSEL OF RECORD: For the Appellant: Name: Firm: For the Respondent: William F. Pentney Deputy Attorney General of Canada Ottawa, Canada [1] 2007 TCC 316. [2] 2009 FCA 70 at paragraph 8. [3] Rules 53 and 58 were amended effective February 26, 2014. ...
TCC
Baldwin v. The Queen, 2014 TCC 284 (Informal Procedure)
the residence of the employer; 2. the residence of the employee; 3. where the employee was paid; 4. where the work was performed; and 5. ... Pentney Deputy Attorney General of Canada Ottawa, Canada ...
TCC
Greer v. The King, 2023 TCC 100
Greer & Son (2006) Ltd. A. Issue #1 – Did the Appellant Receive a Loan from HGSL? ... Q. … you purchased these properties from the company in- on October 4, 2005. ... It was an inheritance. [6] *** Q. Did you ever repay the loan back to the company? ...
TCC
Peyramaure v. The Queen, 2005 TCC 633 (Informal Procedure)
Elizabeth Tan, Translator CITATION: 2005TCC633 COURT FILE No.: 2005-1509(IT)I STYLE OF CAUSE: Gabriel Peyramaure v. Her Majesty the Queen PLACE OF HEARING: Québec, Quebec DATE OF HEARING: September 15, 2005 REASONS FOR JUDGMENT BY: The Honourable Justice Alain Tardif DATE OF JUDGMENT: September 29, 2005 APPEARANCES: For the Appellant: The Appellant himself Counsel for the Respondent: Yanick Houle COUNSE L OF RECO RD: For the Appellant: For the Respo ndent: John H. Sims, Q.C. Deputy Attorney General of Canada Ottawa, Ontario ...
TCC
Canadian Imperial Bank of Commerce v. R., [1997] 3 C.T.C. 2819, 97 D.T.C. 1362
Respondent's Position — Gold and Silver Bullion 23 The Respondent concedes that the first two requirements set out in paragraph 20(1)(gg) of the Act are not in issue. ... Thus when the income of a vending business is calculated in accordance with the well recognized formula used in inventory account: Gross Profit = Proceeds of Sale- Value of Inventory at the beginning of the year + Cost of Inventory acquisitions- Value of Inventory at the end of the year, or: Gross Profit = (Proceeds of Sale- Value of Inventory Sold) + Change in Value of Unsold Inventory. the value of unsold inventory appears as a cost item. and contends that the value of the Appellant's physical gold and silver bullion does not appear as a cost item in the calculation of its income in the relevant fiscal period. ... Minister of National Revenue Respondent's Position — Foreign Currency 35 It is the Respondent's position that “tangible property” and “intangible property” are not mutually exclusive concepts. ...