Search - 赤峰 二中 初中学区划分 2005

     [7]               On July 25, 2005, the Minister issued reassessments for the applicant’s 2001 and 2002 taxation years ...       [8]               On October 24, 2005, the applicant filed a notice of objection to the reassessments ... Woods   DATE OF ORDER:                           January 26, 2011   APPEARANCES:   For the Applicant: The Applicant himself   Counsel for the Respondent: Nalini Persaud   COUNSEL OF RECORD:          For the Applicant:                             Name:                      N/A                               Firm:                                For the Respondent:                    Myles J. ...

K & D Logging Ltd. v. The King, 2023 TCC 23 Docket: 2017-4536(IT)G BETWEEN: K&D LOGGING LTD., Appellant, and HIS MAJESTY THE KING, Respondent.   ... APPENDIX   Relevant Statutory Provisions:   CITATION: 2023 TCC 23 COURT FILE NO.: 2017-4536(IT)G STYLE OF CAUSE: K & D LOGGING LTD. ... Quo Vadis   Firm: Koffman Kalef For the Respondent: François Daigle Deputy Attorney General of Canada Ottawa, Canada   [1] C. ...

No. 489 (QL), 2006 FCA 107, reversing a judgment of Kelen J., [2005] 2 C.T.C. 201, 2005 D.T.C. 5212, [2005] F.C.J. No. 516 (QL), 2005 FC 411.  Appeal allowed.   Graham R. Garton, Q.C., and Wendy Burnham, for the appellants.   ... In the Federal Court, Kelen J. granted the motion and struck the application: [2005] 2 C.T.C. 201, 2005 FC 411.  ...

If he decided not to pursue the account receivable, then normally such amount was irrevocably written off as bad debt. [8]              In August of 2005, the CRA commenced an audit of the Partnership. ... Koshy until 2005. The Appellants only then became aware of the Bad Debt and Unbilled Disbursements. ... the Partnership had three ledger accounts in its PC Law accounting system: Client Disbursements-Recoverable (#1210), Disbursement Clearing (#2005) and Clearing – Disbursement (#2006) (the “Disbursement Clearing Accounts”); b.      ...

  [9]               The Respondent stated in paragraph 14 of the Amended Reply that it had relied on the following assumptions of fact in making its decision:   (a)     the Appellant is in the Business of providing financial services and insurance (the “Business”);   (b)     the Appellant’s fiscal year is from January 1 to December 31;   (c)     the Appellant’s shareholders and their percentages of holdings are:   2006 ·   James Saint                  51% ·   Saint Family Trust         49% 2007 to present ·   James Saint                  100%;   (d)     James Saint is the President of the Business;   (e)     for the relevant period, the Workers were employed by the Appellant under a contract of service;   (f)      the Workers’ positions are as follows:   ·   Shannon MacDonald    Executive Assistant ·   Kevin Lundy                 Sales and Administration ·   Nicolas Anstis              Financial Advisor;   (g)     the Appellant had five employees in 2006, five in 2007 and four in 2008;   (h)     the Appellant set up a trust (“the Trust”) on January  1, 2006 by entering into an agreement;   (i)      the Trustees of the Appellant’s “Trust” are James Saint, James McIntyre and Daryl Phippan;   (j)      James McIntyre and Daryl Phippan were not active in the management of the funds;   (k)     the realized net income is to be allocated to the Participants prior to the end of the year via written direction from the Board of Directors;   (l)      pursuant to the Appellant’s Resolutions, the allocations were to be as follows:   ·   Resolution dated December 23, 2006, the amount of $386,146.86 are [sic] to be paid by December 31, 2006 –   Shannon MacDonald:            $47,026 –   Kevin Lundy:             $33,369 –   James Saint:                           $233,740 –   Nicolas Anstis:                       $72,010 ·   Resolution dated December 23, 2007, the amount of $163,736.88 are [sic] to be paid by December 31, 2007 –   Shannon MacDonald:            $52,979 –   Kevin Lundy:             $38,646 –   James Saint:                           $0.00 –   Nicolas Anstis:                       $72,110   (m)    the Workers received the following T4 employment income from the Appellant:   Name 2005 2006 2007 Nicolas Anstis $40,499 $6,153 $64,356 Kevin Lundy $34,384 $5,000 $4,500 Shannon MacDonald $46,499 $6,384 $4,500 James Saint $230,000 $3,975 $294,406   (n)     in 2006, the Workers received an annual nominal amount between $3,975 and $6,384 on which deductions were taken through the Appellant’s regular payroll;   (o)     in 2007, the Workers received an annual nominal amount between $1,500 and $4,500 on which deductions were taken through the Appellant’s regular payroll;   (p)     the Workers received additional income from the Appellant as follows:   Name 2006 2007 Nicolas Anstis $124,964 $72,110 Kevin Lundy $33,369 $38,646 Shannon MacDonald $47,026 $52,979 James Saint $280,000 $0.00 Total $485,359 $163,736.88   (q)     in 2006, the percentage of additional income compared to T4 income was as follows:   Name 2006 T4 income 2006 additional income Percentage Shannon MacDonald $6,384.62 $47,026.50 726.56% Kevin Lundy $5,000 $33,369 667.38% James Saint $3,975.00 $280,000 7,044.03% Nicolas Anstis $6,153.85 $124,964.37 2,030.67%   (r)     in 2006 2007, the percentage of additional income compared to T4 income was as follows:   Name 2006   2007 T4 income 2006 2007 additional income Percentage Shannon MacDonald $4,500.00 $52,979.75 1,177.33% Kevin Lundy $4,500.00 $38,646.25 858.81% James Saint $294,406.00 $0.00 0.00% Nicolas Anstis $64,356.76 $72,110.88 112.05%   (s)     the payments referred to in paragraph s (q) and (r) above were not based on any determined formula, and contributions were calculated on an ad hoc basis;   (t)      only Nicolas Anstis, Kevin Lundy, Shannon MacDonald and James Saint received additional income from the Appellant in 2006 and 2007;   (u)     the Appellant reported on its financial Balance Sheet, Retained Earnings, as follows:   2005 $1,141,436 2006 $906,921 2007 $1,230,669   (v)     the Appellant reported on its financial Income Statement, Profit, as follows:   2005 $229,866 2006 $371,313 2007 $492,699   (w)    the Appellant reported on its financial Income Statements and on its corporate returns the amounts paid to the Workers as salaries and wages;   (x)     the Workers were paid all income through a bank account number 1093656 in the name of “J.R. ... Saint & Associates Insurance Agencies Ltd.” bank account were as follows:   Years Contributions Withdrawals 2005 2006 $479,233.32 $482,427.18 2006 2007 $185,000.00 $161,657.63 2007 2008 $35,200.00 $35,163.37   (bb)   none of the funds contributed to the J.R. ... Beck     Counsel for the Respondent: Marla Teeling   COUNSEL OF RECORD:          For the Appellant:                             Name:                      Gordon D. ...

In January, 2005 Dupont experienced a fire at that address. All records were destroyed in the fire ...   [9]                On April 29, 2005, Mr. Gomes received a Derivative Director’s Liability Assessment in which he was assessed as being one of the directors of the applicant Dupont and therefore liable under the statute to pay the unremitted tax debt. ... The urgency of the matter was only brought home to him when he received the Director’s Derivative Liability Assessment in 2005 which attributes the corporation’s tax debt to him in his personal capacity ...

Until mid to late 2005, time was simply kept by the drivers without a formal time reporting system although time sheets seemed to have been available. By fall of 2005 or perhaps in the early summer of 2005, a time clock punch card system was apparently introduced but it was not used by all drivers. ... Canada (M.N.R.), 2005 T.C.C. 178, decision of the Federal Court of Appeal dealing with a case involving a delivery driver who owed his own vehicle, the Court stated the following at paragraph 25:   … There is more to financial risk than just providing the worker a guaranteed minimum. ...

Force & Lumière Électriques Inc v. M.N.R., 2007 TCC 25       Docket: 2006‑366(EI)   BETWEEN: FORCE & LUMIÈRE ÉLECTRIQUES INC., Appellant, and   THE MINISTER OF NATIONAL REVENUE, Respondent. ... Mavis Cavanaugh, Reviser       Citation: 2007TCC25 Date: 20070207 Docket: 2006‑366(EI) BETWEEN :   FORCE & LUMIÈRE ÉLECTRIQUES INC.,   Appellant, and   MINISTER OF NATIONAL REVENUE, Respondent.   [OFFICIAL ENGLISH TRANSLATION]   REASONS FOR JUDGMENT   Tardif J.   [1]      This is an appeal from a decision dated November 22, 2005, in which the Minister of National Revenue ("the Minister") decided that the work done by Nasrat Al‑Bashir from April 13, 2003 to April 16, 2004, had been performed under a contract of service ...

Canada, 2005 SCC 54, 2005 DTC 5523 at paragraph 11, the Supreme Court said the following with respect to Canadian tax legislation: Where Parliament has specified precisely what conditions must be satisfied to achieve a particular result, it is reasonable to assume that Parliament intended that taxpayers would rely on such provisions to achieve the result they prescribe. [36]   In A.Y.S.A. ... Canada, [2005] 2 S.C.R. 601, 2005 SCC 54 (CanLII), at para. 11; Placer Dome, at para. 23. ... Drouin Deputy Attorney General of Canada Ottawa, Canada     ...

The Workers [16]   The ten workers who are the subject of these appeals are as follows: Name 2013 2014 Flat rate/subsistence allowance Truck allowance Board and lodging/Trailer allowance Other Colin Averill CPP CPP 2013, 2014       Rodney Bjorkman   CPP, EI 2014       Tammy Borys (McKinnon) CPP CPP, EI 2013, 2014       Aaron Bosch   CPP, EI   2014     Ross French CPP CPP   2013, 2014 2013   John Hague CPP CPP, EI       2013, 2014 Matthew Ingvardsen CPP CPP, EI 2013, 2014       Freddie Powder CPP     2013     Terrence Powder CPP CPP, EI   2013, 2014 2013   Caitlin Rankin CPP     2013       [17]   With respect to John Hague, the earnings in question are remuneration paid for cleaning the Appellant’s trailers in both years. ... The Minister of National Revenue, 2005 TCC 32, [2005] TCJ No. 48. Therefore, there is no adverse finding to be made from the fact that the Appellant’s employees could use the allowances any way they chose. [49]   It is clear from the evidence and not disputed by the Respondent, that the Appellant’s employees were required to work out of town. [50]   Where the number of days worked out of town was provided in the table at Tab 5 of Exhibit A-1, the proposed allowances range from $46.67 per day (Matthew Ingvardsen in 2014) to $92.59 per day (Colin Averill in 2013). [51]   There was no figure provided for out-of-town days worked by Mr. ... Drouin Deputy Attorney General of Canada Ottawa, Canada     ...