Search - 江西农大 毛瑢
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FCTD
The Queen v. Central Tobacco Mfg. (1980), Ltd., 85 DTC 5300, [1985] 1 CTC 357 (FCTD)
In the case of Burnaby Machine & Mill Equipment Ltd. v Berglund Industrial Supply Co Ltd et al, 64 CPR (2d) 206, in which defendants in a copyright infringement action counterclaimed for relief on the grounds that plaintiffs allegations were false and misleading and malicious and sought punitive damages, the plaintiff sought to strike out the paragraphs of the counterclaim. ...
FCTD
Jacobson Holdings Ltd. v. The Queen, 85 DTC 5634, [1986] 1 CTC 87 (FCTD)
I agree with the learned trial judge that a clear and unequivocal positive act implementing a change of intention would be necessary to change the character of the land in question from a trading asset to a capital asset — and that on the facts here present, there was no evidence of such a positive or overt act. ...
FCTD
Lewis v. M.N.R., 84 DTC 6550, [1984] CTC 642 (FCTD)
The said section reads as follows: (4) Search — Where the Minister has reasonable and probable grounds to believe that a violation of this Act or a regulation has been committed or is likely to be committed, he may, with the approval of a judge of a superior or county court, which approval the judge is hereby empowered to give on ex parte application, authorize in writing any officer of the Department of National Revenue, together with such members of the Royal Canadian Mounted Police or other peace officers as he calls on to assist him and such other persons as may be named therein, to enter and search, if necessary by force, any building, receptacle or place for documents, books, records, papers or things that may afford evidence as to the violation of any provision of this Act or a regulation and to seize and take away any such documents, books, records, papers or things and retain them until they are produced in any court proceedings. ...
FCTD
First Fund Genesis Corp. v. The Queen, 90 DTC 6337, [1990] 2 CTC 24 (FCTD)
Under the Scientific & Research Tax Credit (SRTC) scheme, the issuer of the security, Dell, designated an amount of $7.5 million which was purchased by the plaintiff. ...
FCTD
Laxton v. The Queen, 88 DTC 6008, [1988] 1 CTC 19 (FCTD), rev'd , in part, 89 DTC 5327 (FCA)
Thus, it is argued that to now treat the use of the loan as income in his hands, amounts to double taxation — the income potential for the loan has been taxed twice. ...
FCTD
Nova Ban-Corp Ltd. v. Tottrup, 89 DTC 5489, [1989] 2 CTC 304 (FCTD)
.: — Relief Sought The notices of motion filed respectively by Her Majesty the Queen and the other defendants seek identical remedies: namely the grant of leave to file a conditional appearance in order to object to the jurisdiction of the Court, a finding that the Court has no jurisdiction to entertain this action, and in the alternative the striking out of all or part of the statement of claim on other grounds. ...
FCTD
Lee v. The Queen, 92 DTC 6067, [1992] 1 CTC 64 (FCTD)
In 1977, the plaintiff jointly purchased a 114-unit apartment building situated at 33,710 Marshall Road, Abbotsford, British Columbia (the “ Marshall Road Property") with two companies whose shareholders were his acquaintances. ...
FCTD
Timothy P. Neeb v. Her Majesty The Queen, [1991] 1 CTC 41, 90 DTC 6666
The taxpayer had been served three notices of reassessment in one year and the issue before the Tax Review Board was whether the reassessments were ” unfair and unreasonable” treatment by the Minister. ...
FCTD
Brown v. R., [1996] 1 CTC 276
.: — This is an appeal from the decision of the Tax Court of Canada dated June 18, 1991, wherein it was held that subparagraph 40(2)(g)(ii) of the Income Tax Act, R.S.C. 1952, c. 148 (am. ...
FCTD
Her Majesty the Queen v. National Bank of Canada (Supplementary Reasons for Judgment Rendered on February 19, 1993), [1993] 2 CTC 161
The documents consist of correspondence between counsel, correspondence from Coopers & Lybrand Limited and various accounting records and memoranda pertaining to the Thrush receivables. ...