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TCC
Ronda Holdings Limited, Checker Industrial Rubber & Tire Limited, Cartier Parking Limited v. Minister of National Revenue, [1984] CTC 2357, 84 DTC 1331
Ronda Holdings Limited, Checker Industrial Rubber & Tire Limited, Cartier Parking Limited v. ... Law — Cases at Law — Analysis 4.01 Law The main provisions of the Income Tax Act involved in this case are 251(2)(a), 251(5)(a), 256(l)(a) to (e) and 256(2). ... W Ralston & Co (Canada) Ltd v MNR, [1982] CTC 2108; 82 DTC 1128; 9. ...
TCC
A. Hansen & Sons Construction Ltd. v. Minister of National Revenue, [1986] 1 CTC 2576, 86 DTC 1425
Hansen & Sons Construction Ltd. (Hansen Construction) with respect to its 1979 taxation year. ... His evidence as to the appellant’s trading history can be summarized as follows: 1. 1976 — The appellant purchased the Schnell & Barrie Building. ... The acquisition of the Schnell & Barrie building had been a profitable exercise. ...
TCC
K & D Logging Ltd. v. The King, 2023 TCC 23
K & D Logging Ltd. v. The King, 2023 TCC 23 Docket: 2017-4536(IT)G BETWEEN: K&D LOGGING LTD., Appellant, and HIS MAJESTY THE KING, Respondent. ... APPENDIX Relevant Statutory Provisions: CITATION: 2023 TCC 23 COURT FILE NO.: 2017-4536(IT)G STYLE OF CAUSE: K & D LOGGING LTD. ... Quo Vadis Firm: Koffman Kalef For the Respondent: François Daigle Deputy Attorney General of Canada Ottawa, Canada [1] C. ...
TCC
Hi-Rise Electric & Signs Ltd. v. M.N.R., docket 98-159-CPP
Hi-Rise Electric & Signs Ltd. v. M.N.R., docket 98-159-CPP Date: 19990910 Dockets: 98-995-UI; 98-159-CPP BETWEEN: HI-RISE ELECTRIC & SIGNS LTD., Appellant, and THE MINISTER OF NATIONAL REVENUE, Respondent. ... ISSUE: [1] The issue is whether ten employees of the Appellant were, from March 1, 1997 to August 20, 1997 in "insurable employment" as that term is set out in section 5(1) of the Employment Insurance Act (" Act ") and whether they were in pensionable employment within the meaning of the Canada Pension Plan (" CPP "). ...
TCC
Les Placements A & N Robitaille Inc. v. MNR, 96 DTC 1062, [1996] 1 CTC 2141 (TCC)
Wise in determining indicated after-tax earnings of $99,000: 1977 1976 Adjusted pre-tax earnings $ 70,520 $218,010 Weighting factors 2 1 Average indicated pre-tax earnings, rounded off 120,000 Income tax: Indicated earnings $120,000 Less: 3% allowance for inventory ($673,751) (20.213) $ 99,787 LESS: Income tax at 21% on $99,787 (20,955) Indicated after-tax earnings, rounded off $ 99,000 [Translation.] ... His calculation of the indicated aftertax net earnings is as follows: Average adjusted pre-tax net earnings: 1976 * 254,420.00 1977 111,022.00 Total $365,442.00 divided by 2 Indicated pre-tax earnings * 182,721.00 Less: Income tax: Indicated earnings * 182,721.00 Less: 3% allowance for inventory 0000,000) (19,500.00) * 163,221.00 Less: income tax of 21% on $163,221 * (34,277.00) Indicated after-tax net earnings, * 148,444.00 rounded off * 146,400.00 [Translation.] ... Muller & Co.’s Margarine Ltd., [1901] A.C. 217, another House of Lords decision, Lord Macnaghten said at page 223: What is goodwill? ...
TCC
Cornella & Jacob Krahn v. The Queen, docket 2000-2487(IT)I (Informal Procedure)
Cornella & Jacob Krahn v. The Queen, docket 2000-2487(IT)I (Informal Procedure) ...
TCC
Browning Harvey Limited and A. Harvey & Company Limited v. Minister of National Revenue, [1988] 1 CTC 2209, 88 DTC 1164
Harvey & Company Limited v. Minister of National Revenue, [1988] 1 CTC 2209, 88 DTC 1164 Goetz, T.C.J. ... Harvey & Company Limited ("Harvey"), appeals with respect to reassessments by the Minister of its 1982 and 1983 taxation years. ... The money was lost and the losses were capital losses to Stewart & Morrison Limited. ...
TCC
Richard Perren & Co. v. R., [1997] 2 CTC 2501, 97 DTC 1227
Richard Perren & Co. v. R., [1997] 2 CTC 2501, 97 DTC 1227 Brulé T.CJ.: These two appeals were heard on common evidence and involve a payment made to Richard Perren in 1989. ... In reassessing the Appellant’s income the Minister has included the following amounts: The Appellant understands that these personal reassessments relate to the Minister’s treatment of $142,800 ($120,000 U.S.) deposited in the U.S. dollar account of Richard Perren & Company Inc. ...
TCC
D & B Oilfield Contracting Ltd. v. Minister of National Revenue, [1989] 2 CTC 2140, 89 DTC 425
On March 31, 1982, an agreement was signed between D & B Oilfield Contracting Ltd., Sikanni Oilfield Construction Ltd. and Andrew Schuck. ... Central Mortgage & Housing Corp. v. Graham et al. (1973), 43 D.L.R. (3d) 686 (N.S.C.A.T.D.) ... Bank of Toronto, [1922] 3 W.W.R. 922 Robert Porter & Sons Limited v. ...
TCC
Supermarché Dubuc & Frère Inc. v. Her Majesty the Queen (Informal Procedure), [1994] 1 CTC 2215 (Informal Procedure)
Supermarché Dubuc & Frère Inc. v. Her Majesty the Queen (Informal Procedure), [1994] 1 CTC 2215 (Informal Procedure) Garon, J.T.C.C. ... Dubuc stated that he began operating a grocery business on July 1, 1973 under the trade name Dubuc & Frères Enr. ... In the instant case the payment made by Métro-Richelieu was made to induce the taxpayer to conclude the fidelity agreement: — This payment was not associated with the purchase of property, whether equipment, rental improvements or otherwise. — This payment was not associated with expenses incurred or to be incurred by the taxpayer. — The taxpayer had absolute control over the amount received. — The taxpayer was not required to use the said amount for specific purposes. ...