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FCTD

Her Majesty the Queen v. Marsh & McLennan Limited, [1981] CTC 410, 81 DTC 5307

There was no evidence for the plaintiff and one witness for the defendant, John Charles Meuller, chief financial officer of the defendant Marsh & McLennan, Limited. the defendants Harry Price and Hillborn Insurance Limited in related action number T-3556-79, are wholly-owned subsidiaries of Marsh & McLennan, Limited, so that evidence and argument and judgment in this matter apply equally to them. ... I am conscious that the Company likely would not have been overjoyed at such a result, and obviously chose a normal course to obtain maximum revenue. ... In my view, the conclusions of the Board in the March Shipping matter were entirely valid and were properly relied upon in deciding the Marsh & McLennan matter as it did. ...
FCTD

Handy & Harman of Canada Ltd. v. MNR, 73 DTC 5401, [1973] CTC 507 (FCTD)

Handy & Harman of Canada Ltd. v. MNR, 73 DTC 5401, [1973] CTC 507 (FCTD) Heald, J:—This is an appeal from a reassessment by the respondent of the appellant’s income tax for the taxation year ended December 31, 1967. ... The market price for silver is announced each day at noon, by Handy & Harman, appellant’s parent company, in New York. ... This table reads as follows: HANDY & HARMAN OF CANADA LIMITED SILVER PRICES AND VALUES 1946—JUNE 1967 $ PER OZ. ...
FCTD

Orenstein & Partners Inc. In Its Capacity as Court-Appointed Receiver of the Part Viii Tax Refund of Scannar Industries Inc. And Scannar Industries Inc. v. Her Majesty the Queen, [1994] 1 CTC 215

Orenstein & Partners Inc. In Its Capacity as Court-Appointed Receiver of the Part Viii Tax Refund of Scannar Industries Inc. ... The plaintiff, Orenstein & Partners Inc. (Orenstein), is the Court-appointed receiver of the Part VIII tax refund allegedly owing to the other plaintiff, Scannar Industries Inc. ... Finally, the plaintiffs argue that the decision of the Associate Senior Prothonotary was based on the view that the defendant's objections are based on the notion of estoppel that is that the plaintiffs are estopped from relying on the application of subsection 194(4.2) and that this is an argument that should more properly be considered by the trial judge (Plaintiffs’ Outline, supra, paragraphs 10 and 23). ...
FCTD

Stevenson & Hunt Insurance Brokers Ltd. v. The Queen, 93 DTC 5125, [1993] 1 CTC 383 (FCTD), briefly aff'd 98 DTC 6383 (FCA)

I now turn to the relevant provisions of the Income Tax Act subsection 9(1) and paragraph 12(1)(b). ... Premiums earned: Stevenson & Hunt accounted for these on a written as opposed to an earned basis. ... Further, Stevenson & Hunt's fiscal year was not the same as that of the insurance companies. ...
FCTD

Rothmans, Benson & Hedges Inc. v. Minister of National Revenue, [1998] 2 C.T.C. 176

Rothmans, Benson & Hedges Inc. v. Minister of National Revenue, [1998] 2 C.T.C. 176 Richard J.: Nature of the Proceedings 1 The moving party, the respondent Minister of National Revenue, seeks an order striking out the originating notice of motion and dismissing the within proceeding for want of jurisdiction, lack of standing, prematurity and abuse of the process of this Court. 2 In the alternative the respondent seeks an order pursuant to Rule 1614 of the Federal Court Rules (the “Rules”) extending the time limits prescribed in section Part V.1 of the Rules to allow, if necessary, an additional fourteen (14) days from the date of disposition of this motion in which to deliver the respondent's affidavit(s) pursuant to Rule 1603(3) together with leave to raise jurisdictional issues on the return of the application for judicial review. 3 In support of the motion to strike, the moving party relied on the court record consisting of the applicant's (respondent on this motion to strike) originating notice of motion filed November 6, 1997, and the supporting affidavit of Larry Bowen, the Vice President of Leaf and Product Development at Rothmans, Benson & Hedges Inc. ... Canada (Minister of National Health & Welfare), reported in(1994), [1995] 1 F.C. 588 (Fed. ...
FCTD

Rothmans, Benson & Hedges Inc. v. Minister of National Revenue, [1998] 2 C.T.C. 408

Rothmans, Benson & Hedges Inc. v. Minister of National Revenue, [1998] 2 C.T.C. 408 Teitelbaum J.: 1 On February 12, 1998, Rothmans, Benson & Hedges Inc. ... Justice Richard from the case of Rothmans, Benson & Hedges Inc. v. ...
FCTD

Thames Bandag & Tire Ltd. v. The Queen, 88 DTC 6417, [1988] 2 CTC 203 (FCTD)

Thames Bandag & Tire Ltd. v. The Queen, 88 DTC 6417, [1988] 2 CTC 203 (FCTD) Martin, J. ... THAMES BANDAG AND TIRE LIMITED per C/S President THAMES TIRE & AUTO CENTRE (LONDON) INC. per C/S The address of Thames Bandag and Tire Limited and Thames Tire & Auto Centre (London) Inc. is 563 Clarke Road, London, Ontario. ... As a result of the demand by the Royal Bank Thames Bandag and Tire Limited and Thames Tire & Auto Centre (London) Inc. ...
FCTD

Boushehr v. Canada (Minister of Citizenship & Immigration), [1998] 4 CTC 86

Canada (Minister of Citizenship & Immigration), [1998] 4 CTC 86 Simpson, J.: The Applicant seeks judicial review of a decision of an Immigration Officer (the “Officer”) dated January 27, 1998, wherein the Officer decided there were insufficient humanitarian and compassionate (“H & C”) considerations to recommend a favourable decision under Section 114(2) of the Immigration Act, R.S.C. 1985, c. ... The Applicant filed his H & C application under Section 114 of the Act in March 1997 (the “Application”). ... It is for the Applicant to place all pertinent information before the Officer on an H & C review. ...
FCTD

Deloitte & Touche Inc., the Trustee of the Estate of Vancouver Trade Mart Inc., a Bankrupt v. Attorney General of Canada Representing the Minister of National Revenue, [1996] 3 CTC 357

Deloitte & Touche Inc., the Trustee of the Estate of Vancouver Trade Mart Inc., a Bankrupt v. Attorney General of Canada Representing the Minister of National Revenue, [1996] 3 CTC 357 Rouleau J.: This Applicant came before the Court on August 27, 1996, seeking an extension of time to file its motion record. ...
FCTD

Pipe & Piling Supplies LTD v. Her Majesty the Queen, [1979] CTC 445, 79 DTC 5364

Pipe & Piling Supplies LTD v. Her Majesty the Queen, [1979] CTC 445, 79 DTC 5364 Cattanach, J:—For reasons similar to those expressed in the motion in Mike Dym and The Queen (Court File No T-64-77) the motion herein is likewise refused. ...

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