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TCC
Veltri and Son Ltd., Lianna Developments Ltd. and 511060 Ontario Ltd. v. Minister of National Revenue, [1991] 1 CTC 2691, 91 DTC 862
In the French language version of the statute, the corresponding word is “ principaux”. ...
TCC
Fraser v. R., [1996] 2 CTC 2631 (Informal Procedure)
.: — This is an appeal from an assessment of income tax made by the Minister of National Revenue (the “Minister”) on April 11, 1994 with respect to the appellant’s 1992 taxation year. ...
TCC
Pinot Holdings Ltd. v. R., [1996] 1 CTC 2035, 96 DTC 1277
Under this agreement of purchase and sale the partnership agreed to pay the purchase price of $13,500,000 to Salloum Doak, Barristers & Solicitors, in trust, to be disbursed to the Bank of Montreal, the appellant’s creditor prior to the partnership, when clear title to the Capri assets was registered in the name of the partnership. 10. ...
TCC
Fingold v. R., [1996] 1 CTC 2772, 96 DTC 1305
.: — The Appellant appeals from the assessments by the Minister of National Revenue (the “Minister”) for his 1988 and 1989 taxation years whereby the Minister added to his income, pursuant to subsection 15(1) of the Income Tax Act (the “Act”), the amounts of $374,000 for 1988 and $445,675 for 1989 as a shareholder’s benefit from Fobasco Limited (“Fobasco”) with respect to the use by the Appellant of a Florida condominium owned by Fobasco. ...
TCC
Guerette v. R., [1996] 1 CTC 2780 (Informal Procedure)
.: — Before commencing with the evidence counsel for the Appellant made a motion for the change of name of the Appellant from Guerette to Barnard as she had married since the filing of the Notice of Appeal. ...
TCC
Flexi-Coil Ltd. v. R., [1996] 1 CTC 2941
However, as it has often been said in tax cases- although usually where the taxpayer was trying to qualify for a tax benefit and not, as here, where the taxpayer is trying to avoid an adverse tax consequence — that bookkeeping entries do not create reality. ...
TCC
Reginald Watson and Deborah Madayag v. Her Majesty the Queen, [1995] 2 CTC 2460, 96 DTC 2006
Thill & Associates Inc. ("Thill") from Applied Research Ltd. ...
TCC
Healy Financial Corporation v. Her Majesty the Queen, [1994] 2 CTC 2168, 94 DTC 1705
It is agreed that all profits earned by NETWORK will be allocated as follows: (a) Zero to $120,000 to Healy Holdings (b) $120,001 and over — 50 per cent to Healy Holdings and 50 per cent to Weber Holdings. ...
TCC
Gary Orzech, Executor of the Estate of Marcus Orzech v. Her Majesty the Queen, [1994] 2 CTC 2202, 94 DTC 1835
Conclusions (a) Highest & best use Because any use contemplated must be one that is reasonably feasible in an economic sense, it is imperative that appraisers focus on the market conditions as they existed at the relevant time. ...
TCC
Adrian L. Hamoen v. Her Majesty the Queen, [1994] 2 CTC 2278, 94 DTC 1915
On or about January 1, 1986, the appellant was the beneficial owner of an estate in fee simple in respect of various pieces of farmland which had been acquired before 1986 having the following legal descriptions: (i) NW 23-63-2-W5th ("Land No. 1 ") (ii) SW 23-63-2-W5th (“Land No. 2”) (iii) E 23-63-2-W5th (“Land No. 3”) (iv) NE 1-63-4-W5th ("Land No. 4") (v) NE 36-62-4-W5th ("Land No. 5") (vi) SE 6-63-3-W5th (“Land No. 6") In respect of his 1986 taxation year, the appellant had elected that his income from the farming business be computed in accordance with the cash method as defined in subsection 28(1) of the Income Tax Act, R.S.C. 1952, C. 148 (am. ...