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FCTD (summary)
The Queen v. Terra Mining & Exploration Ltd. (N.P.L.), 84 DTC 6185, [1984] CTC 176 (FCTD) -- summary under Scheme
Terra Mining & Exploration Ltd. (N.P.L.), 84 DTC 6185, [1984] CTC 176 (FCTD)-- summary under Scheme Summary Under Tax Topics- Statutory Interpretation- Scheme Since s. 20(1)(c) was thought to be almost a mirror image of s. 12(1)(e), case law as to the meaning of the latter was found to be relevant to the meaning of the former. ...
Decision summary
Re A.G. Canada and Coopers & Lybrand Ltd., 86 DTC 6243 (BCSC) -- summary under Subsection 227(9)
Canada and Coopers & Lybrand Ltd., 86 DTC 6243 (BCSC)-- summary under Subsection 227(9) Summary Under Tax Topics- Income Tax Act- Section 227- Subsection 227(9) A penalty for failure to remit employee source deductions on the due date of February 15, 1985 was not a claim provable in bankruptcy because the proposal under the Bankruptcy Act was filed on February 6, 1985. ...
FCA (summary)
Johnson & Johnson Inc. v. D.MNR, 88 DTC 6235, [1988] 2CTC 1 (FCTD) -- summary under Interpretation Bulletins, etc.
Johnson & Johnson Inc. v. D.MNR, 88 DTC 6235, [1988] 2CTC 1 (FCTD)-- summary under Interpretation Bulletins, etc. ...
TCC (summary)
James McTamney & Co. Ltd. v. MNR, 89 DTC 194, [1989] 1 CTC 2318 (TCC) -- summary under Paragraph 7000(1)(d)
James McTamney & Co. Ltd. v. MNR, 89 DTC 194, [1989] 1 CTC 2318 (TCC)-- summary under Paragraph 7000(1)(d) Summary Under Tax Topics- Income Tax Regulations- Regulation 7000- Subsection 7000(1)- Paragraph 7000(1)(d) Pawners were under no obligation to repay sums paid to them by a pawnbroker unless they redeemed the articles in question. ...
SCC (summary)
James Richardson & Sons v. M.N.R., 84 DTC 6325, [1984] CTC 345, [1984] 1 SCR 614 -- summary under Specific v. General Provisions
James Richardson & Sons v. M.N.R., 84 DTC 6325, [1984] CTC 345, [1984] 1 S.C.R. 614-- summary under Specific v. ...
TCC (summary)
Plaskett & Associates Limited v. Minister of National Revenue, 91 DTC 162, [1991] 1 CTC 2162 (TCC) -- summary under Subsection 153(1.3)
Plaskett & Associates Limited v. Minister of National Revenue, 91 DTC 162, [1991] 1 CTC 2162 (TCC)-- summary under Subsection 153(1.3) Summary Under Tax Topics- Income Tax Act- Section 153- Subsection 153(1.3) Sobier TCJ. accepted a submission that an interim receiver was acting only as a watchman or conservator, and could not make business decisions. ...
FCTD (summary)
Peter Cundill & Associates Ltd. v. The Queen, 91 DTC 5085, [1991] 1 CTC 197 (FCTD), aff'd 91 DTC 5543 (FCA) -- summary under Interpretation Bulletins, etc.
Peter Cundill & Associates Ltd. v. The Queen, 91 DTC 5085, [1991] 1 CTC 197 (FCTD), aff'd 91 DTC 5543 (FCA)-- summary under Interpretation Bulletins, etc. ...
FCA (summary)
The Queen v. B.B. Fast & Sons Distributors, 86 DTC 6106, [1986] 1 CTC 299 (FCA) -- summary under Subsection 45(2)
Fast & Sons Distributors, 86 DTC 6106, [1986] 1 CTC 299 (FCA)-- summary under Subsection 45(2) Summary Under Tax Topics- Statutory Interpretation- Interpretation Act- Subsection 45(2) A comparison of s. 256(1)(e) with s. 39(4) of the pre-1972 Act helped establish that in s. 256(1)(e) Parliament intended that the shareholding of one member of a group was insufficient to fulfill the cross-shareholding requirement in s. 256(1)(e). ...
SCC (summary)
International Power Co. v. McMaster University / In re Porto Rico Power Co., [1946] SCR 178, [1946] 2 DLR 81 -- summary under Investment Contract
McMaster University / In re Porto Rico Power Co., [1946] S.C.R. 178, [1946] 2 DLR 81-- summary under Investment Contract Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(11)- Investment Contract Accrued but unpaid dividends were not a debt because there was no guarantee of payment. ...
Decision summary
Lowe & Ors. v. C.I.R. (New Zealand), [1984] BTC 3 (PC) -- summary under Subsection 10(1)
Lowe & Ors. v. C.I.R. (New Zealand), [1984] BTC 3 (PC)-- summary under Subsection 10(1) Summary Under Tax Topics- Income Tax Act- Section 10- Subsection 10(1) The taxpayers argued unsuccessfully that since "historic cost accounting was unfair", their profit from the sale of land inventory should be reduced to reflect inflation. ...