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T Rev B decision

Latter Investments Limited v. Minister of National Revenue, [1982] CTC 2076, 82 DTC 1086

The word “transformer” is defined in Le Petit Robert Dictionnaire Alphatétique & Analogique de la Langue Française, published in 1973, as follows: TRANSFORMER... 1. ...
T Rev B decision

Wayne Dudley v. Minister of National Revenue, [1982] CTC 2141, 82 DTC 1153

Issue The issue is whether the work performed by the appellant for R M Louson & Co Limited (hereinafter referred to as “Louson”) was done as an employee of Louson and thereby any remuneration being personal income, or whether it was solely the income of The Omemee Tanning Company Limited (hereinafter referred to as “Omemee”), of which the appellant was the sole shareholder. ...
T Rev B decision

Sylvio Paquet v. Minister of National Revenue, [1982] CTC 2144, 82 DTC 1148

Without having to negotiate a price, his father sold him the said land for the sum of $44,000 $2,000 in cash and the balance payable at $2,000 per annum, with interest at 6 per cent. ...
T Rev B decision

Rolf Drescher v. Minister of National Revenue, [1982] CTC 2769, 82 DTC 1769

Interestingly enough, that document recites not that the lottery tickets had been held in trust for all three and that the prize had been collected by the appellant as trustee for all three, rather it recites that “... it is expedient to construe the pooled lottery tickets as purchases on behalf of all of them jointly in equal shares” (emphasis added). ...
T Rev B decision

Hubert Plante, Reynald Plante v. Minister of National Revenue, [1981] CTC 2052, 81 DTC 74

The price of the farm was $40,000; a down payment of $5,000 was made and a first mortgage of $35,000 was obtained at an interest rate of eight %. ...
T Rev B decision

George a Lorenzon, Matteo Francilia, Nazario Matino v. Minister of National Revenue, [1981] CTC 2592, 81 DTC 479

Mr Lorenzon’s participation in the Commercial Drive property was on the basis of equal / share with Mr Francilia and the Carellas. ...
T Rev B decision

Maxwell Janes v. Minister of National Revenue, [1981] CTC 2622, 81 DTC 577

He continued and stated what that benefit was with the policy of insurance and the payment of the premium by London (together with other collateral to the Bank), the appellant gained the ability to acquire and did acquire all the shares of London, with which he could do as he willed (and he did by having them registered in the name of Marc), subject of course to the terms imposed by the bank. ...
T Rev B decision

Paul Burden LTD v. Minister of National Revenue, [1981] CTC 2847, 81 DTC 651

As to the name “Extended Warranty Agreement”, counsel for the appellant relied on Front & Simcoe Ltd v MNR, [1960] CTC 123; 60 DTC 1081, in which the following statement of Viscount Simon was referred to with approval at 132 [1085]: It may be well to repeat two propositions which are well established in the application of the law relating to income tax. ...
T Rev B decision

Robert Lapalus v. Minister of National Revenue, [1980] CTC 2035

In 1975 and 1976, he earned more than $24,000 a year according to his income tax returns, that is, over $460 a week ($460 x 8 = $3,680). ...
T Rev B decision

Ernest Abramovici v. Minister of National Revenue, [1980] CTC 2162, 80 DTC 1151

The appellant set out the general principles for the Board, and I quote from the Traité Elementaire de Droit Civil Les Obligations, by Jean-Louis Baudouin, at p 301: [TRANSLATION] 571— General principles—Moratory damages are due to the creditor as a result of the debtor’s mere delay in performing the obligation. ...

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