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FCA
Intermodal Container Transport Ltée v. Beauchamp, docket ITA-1716-98
Beauchamp, docket ITA-1716-98 Date: 1999 Docket: IT A-1716-98 MONTRÉAL, QUEBEC, THE DAY OF , 1999 Present: Mr. ... This order applies to and will be placed in file IT A-9734-98. ... I. Instalment sale of property [10] An initial series of contracts involves seized property number 9: 1 green truck with rotary flange, NS/FCIN3012RW33493. [11] This property is alleged to be the Beauchamps' by the following reasoning. [12] It was allegedly assigned to the Beauchamps by Beau-Co Corporation Inc. ...
FCA
Bonev v. Canada, 2020 FCA 138
HER MAJESTY THE QUEEN DEALT WITH IN WRITING WITHOUT APPEARANCE OF PARTIES REASONS FOR ORDER: LEBLANC J.A. ... RIVOALEN J.A. DATED: September 4, 2020 WRITTEN REPRESENTATIONS: Roumène Bonev For the appellant (representing himself) Julien Wohlhuter Vlad Zolia For the respondent SOLICITORS OF RECORD: Nathalie G. Drouin Deputy Attorney General of Canada For the respondent ...
FCA
Struck v. Canada, 2017 FCA 69
WOODS J.A. BETWEEN: HORST STRUCK Appellant and HER MAJESTY THE QUEEN Respondent REASONS FOR JUDGMENT WEBB J.A. [1] Mr. ... I. Background [2] Mr. Struck transferred 150 shares of 468543 B.C. ... II. Issue [6] The issue in this appeal is whether the Tax Court Judge committed any error in quashing Mr. ...
FCA
Bonnybrook Industrial Park Development Co. Ltd. v. Canada (National Revenue), 2018 FCA 136
WOODS J.A. BETWEEN: BONNYBROOK PARK INDUSTRIAL DEVELOPMENT CO. LTD. ... MINISTER OF NATIONAL REVENUE PLACE OF HEARING: Toronto, Ontario DATE OF HEARING: JANUARY 9, 2018 REASONS FOR JUDGMENT BY: WOODS J.A. CONCURRED IN BY: NEAR J.A. DISSENTING REASONS BY: STRATAS J.A. DATED: July 18, 2018 APPEARANCES: Justin Kutyan Thang Trieu For The Appellant Craig Maw Nancy Arnold For The Respondent SOLICITORS OF RECORD: KPMG Law LLP Toronto, Ontario For The Appellant Nathalie G. ...
FCA
Grenon v. Canada (National Revenue), 2017 FCA 167
GLEASON J.A. Date: 20170809 Docket: A-239-16 Citation: 2017 FCA 167 CORAM: WEBB J.A. ... I. Background [3] Some time prior to March 7, 2013 Mr. ... II. Decision of the Federal Court [8] Mr. ...
FCA
MNR v. Yonge-Eglinton Building Ltd., 74 DTC 6180, [1974] CTC 209 (FCA)
The amounts in question are the following: 1965 — $11,695.45 1966 — $12,263.98 1967 — $12,584.86 1968 — $13,143.12 The learned trial judge held that these amounts were not interest and therefore were not deductible under paragraph 11(1)(c)* [1] of the Income Tax Act but that they were deductible under paragraph 11 (1)(d)t [2] as parts of payments repaying borrowed money used for the purpose of earning income from a business or property that were required by section 7J [3] to be included in computing the income of the recipient. ... Pursuant to that section 3(b) the respondent made payments to Traders as follows: 1965 — $11,695.45 1966 — $12,263.98 1967 — $12,584.86 1968 — $13,143.12 Those are the payments which the appellant disallowed and which are the subject matter of this appeal. ... In my opinion, the following items respectively claimed by the respondent to be deductible in computing its income in the following years, namely 1965 — $11,695.45 1966 — $12,263.98 1967 — $12,584.86 1968 — $13,143.12 were not so deductible and that the appellant was correct in disallowing them. ...
FCA
Athletes 4 Athletes Foundation v. Canada (National Revenue), 2020 FCA 41
B. Application of the rules in this case [23] I will first deal with the second of the Foundation’s three requests for further disclosure. ... DATED: FEBRUARY 7, 2020 WRITTEN REPRESENTATIONS BY: Blake Bromley Josh Vander Vies For The Appellant Lynn Burch Selena Sit Anna Walsh For The Respondent SOLICITORS OF RECORD: Benefic Law Corporation Vancouver, British Columbia For The Appellant Nathalie G. Drouin Deputy Attorney General of Canada For The Respondent ...
FCA
High-Crest Enterprises Limited v. Canada, 2017 FCA 88
II. Procedural Background [9] The matter was heard on February 26, 2014 by a judge of the Tax Court. ... B. Discretion [85] Assuming the Chief Justice has a power to reassign, he is not forced to exercise it. ... Pentney Deputy Attorney General of Canada For The Respondent ...
FCA
Roberto Aquilini et al. v. Her Majesty the Queen, 2021 FCA 206
Beginning in 2001, a reorganization was undertaken to consolidate the interests under one limited partnership – AIGLP. ... A fair reading of his reasons reflects the focus on the allocation of the income of AIGLP and the losses of the GERI partnership. [50] The only partners of the GERI partnership, as set out in paragraph 99 of the Partial Agreed Statement of Facts and Schedule “A” to that agreement, were: ● Elisa Aquilini ● Francesco Aquilini ● Roberto Aquilini ● Paolo Aquilini ● Global Coin Corporation ● Cranberry Plantation Inc. [51] None of the EAFT, the FAFT, the RAFT, or the PAFT were partners of the GERI partnership. ... François Daigle Deputy Attorney General of Canada For The Respondent ...
FCA
Newcourt Financial Ltd. v. Canada, 2006 DTC 6627, 2004 FCA 91
Les créanciers du saisi ne peuvent s'opposer à la saisie ni à la vente. ... Gauthier, C Tr, LLL FEDERAL COURT OF APPEAL SOLICITORS OF RECORD DOCKET: A-529-02 STYLE OF CAUSE: Newcourt Financial Ltd. v. Her Majesty the Queen in Right of Canada PLACE OF HEARING: Montréal, Quebec DATE OF HEARING: February 4, 2004 REASONS FOR JUDGMENT BY: Noël J.A. ...