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TCC

James McTamney & Co. Ltd. v. MNR, 89 DTC 194, [1989] 1 CTC 2318 (TCC)

James McTamney & Co. Ltd. v. MNR, 89 DTC 194, [1989] 1 CTC 2318 (TCC) Christie, A.C.J.T.C.: —This appeal relates to the appellant's 1983 taxation year. ... The form of notice of forfeiture sent by mail to a pawner by the appellant reads: DEAR SIR or MADAM: Your Loan No. of For$ is past due. ... Very truly yours, JAMES MCTAMNEY & CO. LTD. THIS LOAN COVERS Interest & Storage due. ...
TCC

Plaskett & Associates Limited v. Minister of National Revenue, 91 DTC 162, [1991] 1 CTC 2162 (TCC)

Plaskett & Associates Limited v. Minister of National Revenue, 91 DTC 162, [1991] 1 CTC 2162 (TCC) Sobier,T.CJ. ... In particular, she referred to In re Stuart & Sutterby (1929), 2 C.B.R. 1 (Ont. ... This decision was appealed to the Supreme Court of Ontario and reported as In re Stuart & Sutterby (1930), 2 C.B.R. 279. ...
TCC

Atlantic Mini & Modular Homes (Truro) v. The Queen, docket 98-1693-GST-I (Informal Procedure)

Atlantic Mini & Modular Homes (Truro) v. The Queen, docket 98-1693-GST-I (Informal Procedure) Date: 19990719 Docket: 98-1693-GST-I BETWEEN: ATLANTIC MINI & MODULAR HOMES (TRURO) LTD., Appellant, and HER MAJESTY THE QUEEN, Respondent. ... The Minister is of the opinion that the used mobile homes sold by the Appellant are residential complex within the meaning of the Excise Tax Act (the " Act ") and it follows that GST should be remitted on the taxable supplies provided by the Appellant. ... " [16] A "residential complex" includes a mobile home as defined under subsection 123(1) of the Act which says: "... ...
TCC

Impenco Ltd. — Impenco Ltee v. Minister of National Revenue, [1988] 1 CTC 2339, 88 DTC 1242

. Impenco Ltee v. Minister of National Revenue, [1988] 1 CTC 2339, 88 DTC 1242 Couture, C.J.T.C. ... It was established in cross-examination that between 1981 and 1986 the appellant had the following gross and net income and made these contributions to charitable organizations: Gross Income Net Income For Charitable Donations Tax Purposes 1981 $4,026,113 $ 82,507 1982 5,186,382 $ 546,597* [1] 104,226 1983 6,436,017 1,154,097 * 186,115 1984 4,577,312 456,065 178,097 1985 5,472,160 368,288* 186,307 1986 5,279,177 388,395 188,985 Mr. ... In Olympia Floor & Wall Tile v. M.N.R., [1970] C.T.C. 99; 70 D.T.C. 6085 Jackett, P. ...
TCC

Northwood Pulp & Timber Ltd. v. R., [1996] 2 CTC 2123, 96 DTC 1104

Justice MacGuigan in West Kootenay Power & Light Co. v. R., (sub nom. ... Nomad Sand & Gravel Ltd. v. Canada), [1991] 1 C.T.C. 60, (sub nom. ... In the case of Newfoundland Light & Power Co. v. R., (sub nom. Newfoundland Light & Power Co. v. ...
TCC

Majestic Tool & Mold Limited v. Her Majesty the Queen (Informal Procedure), [1993] 2 CTC 2813

Majestic Tool & Mold Limited v. Her Majesty the Queen (Informal Procedure), [1993] 2 CTC 2813 Kempo, T.C.CJ. ... & M. Investments Ltd., Mr. Boggs prepared unaudited combined statements for fiscal year endings of October 31, 1989 and 1990. ... Financial statements were forwarded to Dun & Bradstreet by him which included mention of the term deposits as assets. ...
TCC

212535 Oil & Gas Ltd. v. MNR, 96 DTC 1263, [1996] 1 CTC 2416 (TCC)

212535 Oil & Gas Ltd. v. MNR, 96 DTC 1263, [1996] 1 CTC 2416 (TCC) Rip J.T.C.C. The main issue in these appeals [1] is whether a certain outlay is an expense incurred in the course of carrying on a business and is deductible in determining the appellants’ income from business for the year in accordance with section 9 of the Income Tax Act (“Act”). The facts in the appeals of 212535 Oil & Gas Ltd., 212634 Oil & Gas Ltd., 212873 Oil & Gas Ltd. and 228262 Alberta Ltd. from income tax assessment for their 1981 taxation year [2] are similar, if not identical, to those in the appeal of St. ... Ives, supra, was whether the sum of $1,250,000 which that taxpayer had agreed to pay Carter Oil & Gas Ltd. ...
TCC

Sharon Buckland v. Minister of National Revenue and Donald Buckland and D.]. Buckland & Associates Ltd. (Third Parties) v. Minister of National Revenue, [1991] 1 CTC 2022, 91 DTC 131

Buckland & Associates Ltd. (Third Parties) v. Minister of National Revenue, [1991] 1 CTC 2022, 91 DTC 131 Brulé, T.C.J. ... Buckland & Associates Ltd. as third parties to the appeal. In his successful application the Minister requested a determination of the following questions: (1) Does the amount of $14,024 paid to Sharon Buckland by the company constitute income from employment? ...
TCC

B & M Carriers v. Her Majesty the Queen, [1993] 2 CTC 2801, 93 DTC 1205

B & M Carriers v. Her Majesty the Queen, [1993] 2 CTC 2801, 93 DTC 1205 Sarchuk, T.C.C.J. ... And in this case, what it permitted was the ability to pay over time out of profits profits which would not be subject to or [sic] remittance to, Her Majesty pay that to the creditors. ... Canada Employment & Immigration Commission, [1985] 2 S.C.R. 417, 23 D.L.R. (4th) 641; Beauchesne Inc. v. ...
TCC

Roberge & Fils Inc. v. The Queen, docket 95-3417-IT-G

Roberge & Fils Inc. v. The Queen, docket 95-3417-IT-G Date: 19980715 Docket: 95-3417-IT-G BETWEEN: eROBERGE & FILS INC., Appellant, and HER MAJESTY THE QUEEN, Respondent. ... Roberge & Fils acted only as a "vehicle" for the eventual transfer to 2745-8017 Québec Inc. What is more, the hypothec held by Roberge & Fils Inc. could have been challenged, as therefore could the giving in payment. ...

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