Search - 江西农大 毛瑢

The sale was a private one — the land was never listed with a real estate agent. ... Nothing has happened to date to frustrate those plans and she still owns the land — now with a completely clear title. ...

Carnaby, Narrower, Barham & Pykett, [1970] 1 All E.R. 502; [1970] 1 W.L.R. 276 as a case that parallels the one before me. ... Plaintiff contends that the defendant, in 1985, amended the Income Tax Act by adding paragraph 12(1)(x) which states: 12.(1)(x) payments as inducement or as reimbursement etc. — any amount (other than a prescribed amount) received by the taxpayer in the year, in the course of earning income from a business or property, from (i) a person who pays the amount (in this paragraph referred to as “the payor”) in the course of earning income from a business or property or in order to achieve a benefit or advantage for himself or for persons with whom he does not deal at arm's length, or (ii) a government, municipality or other public authority where the amount can reasonably be considered to have been received (iii) as an inducement, whether as a grant, subsidy, forgivable loan, deduction from tax, allowance or any other form of inducement, or (iv) as a reimbursement, contribution, allowance or as assistance whether as a grant, subsidy, forgivable loan, deduction from tax, allowance or any other form of assistance, in respect of the cost of property or in respect of an expense to the extent that the amount (v) was not otherwise included in computing the taxpayer’s income for the year or a preceding taxation year. ...

The following two paragraphs (at page 3) under the heading “ Roll Recovering Expenses" bear reproduction. ... There is no doubt that the covering of the steel rolls is replaced but the recovering has to be replaced because it is worn, not because it is "decayed" or “ damaged”. ...

Fleming & Co. (Machinery), Ltd. (1951), 33 T.C. 57 (Ct. of Sess.). 3 See e.g., The Glenboig Union Five Clay Co., Ltd. v. C.I.R. (1922), 12 T.C. 427 (H. of L.) at 39-40; Barr, Crombie & Co., Ltd. v. ...

The plaintiff was federally incorporated in Canada in 1971 as a wholly- owned subsidiary of Angostura Bitters (Dr J G B Siegert & Sons) Limited, a Trinidad corporation which fell heir to the secret formula of the famed aromatic elixir “Angostura Bitters’’ discovered in 1824 by Dr Siegert, while Surgeon-General in the revolutionary army of the great Venezuelan liberator, Simon Bolivar. ... Since 1968, Angostura Bitters (Dr J G B Siegert & Sons) Limited had been thinking about taking over the distribution and marketing of Angostura Bitters in the United States and had made its intentions known to All World and its parent corporation, Iroquois Brands, Ltd. ...

The plaintiffs: Murray Watts was a mining engineer, geologist as well as a prospector; Frederick W Henderson was a registered representative of various investment dealers in the city of Toronto and at the relevant time was a shareholder of Playfair & Company Ltd Investment Dealers; William G Leliever was a prospector. ... Since the early 1960s Henderson, through Playfair & Company Ltd, had been acting for a New York Institutional investor known as Value Line Special Situations Fund; it was a great source of capital for junior companies. ...

On November 13, 1980, Revenue Canada issued a notice to Paramount Pictures Corporation (Canada) Ltd. showing total instalment payments of $1,042,000 ($792,000 + $250,000) which had been credited to account number 7-949-811-9. ... & Communikon Services Ltd. on July 31, 1979. This new corporation carried on business under the name Paramount Pictures Corporation (Canada) Ltd. with the first fiscal period ending 22-02-80. ...

—On ex parte application by the Minister, a judge may, subject to such conditions as he considers appropriate, authorize the Minister to impose on a third party a requirement under subsection (1) relating to an unnamed person or more than one unnamed person (in this section referred to as the " roup”) where the judge is satisfied by information on oath that (a) the person or group is ascertainable; (b) the requirement is made to verify compliance by the person or persons in the group with any duty or obligation under this Act; (c) it is reasonable to expect, based on any grounds, including information (statistical or otherwise) or past experience relating to the group or any other persons, that the person or any person in the group may have failed or may be likely to fail to provide information that is sought pursuant to the requirement or to otherwise comply with this Act; and (d) the information or document is not otherwise more readily available. (4) Service of authorization. ... Canada, [1990] 1 S.C.R. 627; [1990] 2 C.T.C. 103; 90 D.T.C. 6243, at 109 (D.T.C. 6247; S.C.R. 639), Madam Justice Wilson recalled the proper construction to be given to subsection 231(3) of the Income Tax Act‘, which is the predecessor to subsection 231.2(1): This Court had occasion to consider subsection 231(3) of the Act in James Richardson & Sons, Ltd. v. ...

Ct.) and Racine, Demers & Nolin v. M.N.R., [1965] C.T.C. 150, 65 D.T.C. 5098 (Ex. ... The provision now reads as follows: 220(3.1) Waiver of penalty or interest. — The Minister may at any time waive or cancel all or any portion of any penalty or interest otherwise payable under this Act by a taxpayer or partnership and, notwithstanding subsections 152(4) to (5), such assessment of the interest and penalties payable by the taxpayer or partnership shall be made as is necessary to take into account the cancellation of the penalty or interest. ...

Appeal allowed. 69; MNR v John Colford Contracting Co Ltd, [1960] Ex CR 433, aff'd by SCR 1962; [1960] CTC 178; 60 DTC 1131; The Queen v Imperial General Properties Ltd, [1985] 1 CTC 40; 85 DTC 5045; Isaac Holden & Sons Ltd v CIR, 12 TC 768; Kenneth B S Robertson Ltd v MNR, [1944] Ex CR 170; [1944] CTC 75; 2 DTC 655; Maple Leaf Mills Ltd v MNR, [1977] 1 S.C.R. 558, [1976] CTC 324; 76 DTC 6182; CIR v Newcastle Breweries Ltd, 12 TC 927; The Naval Colliery Co Ltd v CIR, 12 TC 1017; MNR v Shofar Investment Corp, [1979] CTC 433; 79 DTC 5347; Willingale (Inspector of Taxes) v International Commercial Bank Ltd, [1978] 1 All ER 754 (HL); M H Courrier Inc v The Queen, [1976] CTC 567; 76 DTC 6331; MNR v Benaby Realties Ltd, [1967] CTC 418; 67 DTC 5275; Edmonton Liquid Gas Ltd v The Queen, [1984] CTC 536; 84 DTC 6526; Francon Ltée v The Queen, [1973] CTC 708; 73 DTC 5514. 1 *SC 1970-71-72, c 63, telle qu'amendée. 2 *En l’occurrence, le deuxième paragraphe non chiffré de l’article 7. 3 ★Associated Investors of Canada Ltd v MNR, [1967] CTC 138; 67 DTC 5096; MNR v Atlantic Engine Rebuilders Ltd, [1967] S.C.R. 477; [1967] CTC 230; 67 DTC 6155; Cana dian Fruit Distributors Ltd v MNR, [1954] CTC 284; 54 DTC 1145; Canadian General Electric Co Ltd v MNR, [1962] S.C.R. 3; [1961] CTC 512; 61 DTC 1300; Commonwealth Construction Co Ltd v The Queen, [1984] CTC 338; 84 DTC 6420; Dominion Taxicab Association v MNR, [1954] CTC SCR 42; [1954] CTC 34; 54 DTC 1020; Alger B Ferriss v MNR, [1965] 2 Ex CR 525; [1964] CTC 491; Freeway Properties Inc v The Queen, [1985] 1 CTC 222; 85 DTC 5183; CIR v Gardner, Mountain & d'Ambrumenil Ltd, [1947] 29 TC 4-[Maple Leaf Mills Limited c MNR, [1977] 1 RCS 558, à la page 566; [1976] CTC 324 à la page 330. 5 ^Canadian Fruit Distributors Limited c MNR, [1954] CTC 284, à la page 292; 54 DTC 1145 à la page 1149. ...