Search - 深圳居住证 办理条件 最新政策

Tom Baird & Associates Ltd. v. Minister of National Revenue, [1998] 1 CTC 69 Létourneau J.A.: Once again, we are thrown back into the quagmire of the Excise Tax Act. ... I need only refer to this passage of Major J. of the Supreme Court of Canada in the recent case of Friesen v. /?. ... Wampole & Co. [10] as well as in British Columbia Telephone Co. v. ...

Its findings were not reassuring and meetings were held at which were present representatives of the Bank and Coopers & Lybrand. ... On September 24, 1976 the bank delivered to the respondent, a company performing services as receiver and an affiliate of the accounting firm of Coopers & Lybrand, a letter of appointment in the following terms: “September 24, 1976’’ Coopers & Lybrand Limited, 145 King Street West, Toronto, Ontario. ... Yours very truly, COOPERS & LYBRAND LIMITED Receiver and Manager Robert E Lowe, President. ...

Newfoundland Light & Power Co. Ltd. v. The Queen, 90 DTC 6166, [1990] 1 CTC 229 (FCA) Desjardins, J.A.: — The appellant, a Newfoundland company based in St. ... ", [13] or ”... the total cost to a taxpayer of acquiring a depreciable asset... ... Terms of payment: % of the monthly estimates submitted and accepted, the balance namely %, 35 days after final approval of the work by the architect. 5. ...

Deputy Minister of National Revenue for Customs & Excise v. Steel Company of Canada Limited, [1983] CTC 258, 83 DTC 5301 Heald, J:—This is an appeal on a question of law pursuant to leave granted by this Court, from a declaration of the Tariff Board dated January 13, 1982. ... Subsection 1(a) of Part XIII uses the words “... imported by manufacturers or producers for use by them...” ... The decision of the Supreme Court of Canada in the case of Irving Oil Ltd v The Provincial Secretary of the Province of New Brunswick [1980] 1 S.C.R. 787, is authority for the view that “... the requirement of direct use is fulfilled irrespective of the percentage of use that may be ascribed to the process of manufacture as opposed to other processes such as storage and distribution.” [5] Accordingly, it is my conclusion that while the Tariff Board did not err in law in deciding that the columns in issue are parts of the cranes and therefore not subject to the sales or consumption tax imposed by section 27 of the Excise Tax Act, it erred in declaring that only the portions of the columns designed to support the overhead cranes are exempt from the sales tax. ...

Fast & Sons Distributors, 86 DTC 6106, [1986] 1 CTC 299 (FCA) Urie, J. ... DeFehr & Sons, as a furniture merchant. The shareholdings in the respondent were at all material times as follows: William Fast 100 shares (20 per cent) Dr. ... Only one of the members of the group owned that 20% and one human individual of a group — even a group of two — cannot be equated with the whole group. ...

Qit-Fer & Titane Inc. v. R., [1996] 2 CTC 30 Marceau J.A.:- In our view, this appeal must not succeed. ...

B & J Music Ltd., 83 DTC 5074, [1983] CTC 50 (FCA) Thurlow, CJ:—The issue in this appeal is whether the taxable income of the respondent for the taxation years 1972, 1973, and 1974, when the respondent did not qualify for a tax deduction as a Canadian controlled private corporation, must be brought into account in computing its “cumulative deduction account” for the purposes of subsection 125(1) of the Income Tax Act, for the taxation years 1975, 1976 and 1977 when the respondent did qualify as a Canadian controlled private corporation. ... His view was expressed in the following paragraph from his reasons: In my view, section 125 of the Income Tax Act is a special section affording “Canadian-controlled private corporation” special tax treatment and it does not in any of its provisions refer to any other corporations; and further Parliament did not legislate in this section to deny the so-called small business deduction to any corporation such as B & J Music Limited which was not in 1971 a “Canadian controlled private corporation”. ...

Peter Cundill & Associates Ltd. v. Her Majesty the Queen, [1991] 2 CTC 221, 91 DTC 5543 Mahoney, J.A. [Marceau and MacGuigan, JJ.A concurring]:—This is an appeal from a reported decision of the Trial Division [1991] 1 C.T.C. 197; 91 D.T.C. 5085, which dismissed the appellant's appeal against its 1985 and 1986 income tax assessments imposing a 25 per cent withholding tax on fees paid to it to Peter Cundill & Associates (Bermuda) Ltd., hereafter "the Bermuda company". ...

Deputy Minister of National Revenue (Customs & Excise), [1997] 1 CTC 2407 Hugessen J.A.: — Section 15 of the Special Import Measures Act sets out the general rule for the calculation of “normal value” Subject to sections 19 and 20, where goods are sold to an importer in Canada, the normal value of the goods is the price of like goods when they are sold by the exporter of the first mentioned goods (a) to purchasers (i) with whom the exporter is not associated at the time of the sale of the like goods, and... ...

Collier & Son Ltd. v. The Deputy Minister of National Revenue for Customs and Excise, [1986] 2 CTC 375 Stone, J. ... Russell & Sons Ltd., [1973] 1 Q.B. 336 (C.A.). That case involved the time within which an action could be commenced for a fatal accident and it was held that the action had been commenced “within three years” laid down by the statute when it was commenced on the next day after that period had expired, the court office being closed on the last day of the period which was a Sunday. ...