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TCC

Nashen & Nashen Consultants Inc. v. The Queen, docket 2000-3621-IT-I (Informal Procedure)

It encompasses a number of design tools to duplicate the various features of any paper form such as:-                Lines-                Boxes-                Arcs and circles-                Texts and text formats-                Tables-                Check boxes-                Buttons-                Data fields. ... It is not compatible with popular graphic formats such as PC Paintbrush bitmap (PCX), Tag Image File Format (TTIFF), Graphics Interchange Format (GIF), JPEG compressed bitmap (JPEG) and Portable Document File (PDF) (Adobe Acrobat- displayable with a Web browser). ... Papion stated as follows: By the end of the 1998 fiscal year, following tests with JPEG, GIF and PDF standards the 1999 planned research program called for the development of a Framework that combined:-                Form Design Toolkit-                Form Filler Frontend-                And Central Advanced Function Printing [13]          To be successful, the Appellant has to establish on a balance of probabilities, the work done was SRED. ...
TCC

Naghash v. M.N.R., 2005 TCC 694

)   [12]     Continuing with his testimony, the appellant stated he began searching for PDF opportunities while employed in Singapore. ... Are there other universities that like the University of Alberta do not treat any PDFs as employees?   ...   [35]     The facts in the within appeals are that the appellant applied for and received a PDF to join a research group headed by Drs. ...
TCC

Bekhor v. M.N.R., 2005 TCC 443

  [15]     Regarding termination, it is stated that a PDF appointment may be terminated at any time for just cause on the recommendation of the faculty member responsible for the PDF. ... Are there other universities that like the University of Alberta do not treat any PDFs as employees?   ... No, not to my knowledge.   Q. Doctor Goldberg, which would be the more common type of PDF funding, funding directly to the PDF from the external agency or funding through a research grant that had been awarded to a University Professor?   ...
TCC

Zhang v. The Queen, 2010 TCC 592 (Informal Procedure)

She conducted her PDF training program at the BC Cancer Research Centre in hematology under the supervision of Dr.  ...   [8]               According to the Appellant, PDFs are considered by UBC to be trainees not employees. ... As no certificate has been obtained from UBC, the Appellant is not entitled to the education credit with respect to her PDF training program ...
TCC

University of New Brunswick v. M.N.R., 2023 TCC 72

Signed at Ottawa, Canada, this 25 th day of May, 2023.   “R.S. Bocock” Bocock J. ... The gamut spanned aspirational goals: (i) opportunity for [PDFs]… to carry on individual research; to participate fully in.. research, teaching and supervisory activities at the.. ... HMQ, 2012 TCC 212 (“ Caropreso ”). At paragraph 20 in that appeal, specifically involving PDFs, Justice Woods states: The root of the difficulty is that payments to postdoctoral research fellows often have dual elements. ...
TCC

Mazraani v. M.N.R., 2016 TCC 65

La version électronique en format PDF de cette proposition est également disponible sur l’extranet et dans le centre de documentation. 3. ... Lorsque vous en commanderez, veuillez prendre en considération que nous préparerons éventuellement une version en format PDF dynamique (qui peut être remplie à l’écran). ... Traitement des objections ”. Other activities included the Souper pour les gagnants du Concours and a Soirée Gala ”. ...
TCC

Johnson v. M.N.R., 2018 TCC 201

[Emphasis added.]   Attached to the email is a PDF file entitled “NC Step by step instructions”. ... Johnson regarding an event for November 12, 2015: [19] Lockers are provided at this venue *** please bring your own lock ***. ... In fact, BDI provided its services also outside the Toronto area, in particular, in the Niagara Falls area. [2]   Exhibit A-1 at Tab 6. [3]   In bold characters in the text. [4]   See Exhibit I-2, paragraph 1c of the Independent Contractor Agreement (BDI Agreement). [5]   Exhibit I-1, Tab 6. [6]   Exhibit I-1, Tab 6. [7]   Exhibit I-1, Tab 1. [8]   Exhibit I-2. [9]   Exhibit A-1, Tab 3. [10]   Exhibit A-1, Tab 14. [11]   Exhibit A-1, Tab 25. [12]   Exhibit A-1, Tab 12. [13]   Exhibit A-1, Tab 8. [14]   Exhibit A-1, Tab 9. [15]   Exhibit A-1, Tab 10. [16]   Exhibit A-1, Tab 11. [17]   Exhibit A-1, Tab 18. [18]   Exhibit A-1, Tab 19. [19]   Exhibit A-1, Tab 20. [20]   Exhibit A-1, Tab 21. [21]   See Exhibit A-3. ...
TCC

Hill v. The Queen, 2012 TCC 202

Signed at Ottawa, Canada, this 7th day of June 2012.       “B. Paris” Paris J.         ... We will send you a copy in PDF file once we receive it.   He has asked that it be signed by Friday of this week for this new offer to be accepted.   ... Taxation Years 1999, 2000, 2001, 2003, and 2004   I waive any right of objection or appeal in respect of:   •           Unreported Income •           Disallowed Expenses •           Denied Non‑Capital Loss   if Canada Revenue Agency reassesses as follows     Gross Business Income             1999 2000 2001 2003 2005 Appeals Proposed Changes            -3,700.00-19,492.00-59,698.63-67,785.63-258,841.34     I have read the above subsections of the Income Tax Act and understand that I will be precluded from filing an objection or an appeal with respect to the above noted taxation years.     ...
TCC

Hypercube Inc. v. The Queen, 2015 DTC 1135 [at at 859], 2015 TCC 65 (Informal Procedure)

  [13]         The initial hypothesis on which the project was based, as Mr.  ... The program had to be able to produce a diagnostic report in PDF format. [18]         Mr.  ... Pentney Deputy Attorney General of Canada Ottawa, Canada     ...
TCC

Shenanigans Media Inc. v. The Queen, 2017 TCC 180 (Informal Procedure)

The remainder of the reduction comprises makeup and hair and wardrobe expenses that were allowed by the Appeals Division because they were considered to have been incurred for business purposes. [10]          Below I set out in more detail the disputed expenses: Taxation Year Category Total Expenses Claimed Total Expenses Allowed 2009 (DE) Advertising $2,566 $2,566   Business Promotion $2,129 $1,006   Makeup/Hair $3,342 $1,671   Management/Chaperone $10,000 $10,000   Research and Development $1,554   Rent $2,010 $2,000   Travel $13,957 $4,261   Wardrobe $3,013 $1,506 2010 (DE) Business Promotion $1,378 $347   Makeup/Hair $1,518 $759   Management/Chaperone $14,000 $10,000   Research and Development $463   Rent $4,000   Travel $3,209 $634   Wardrobe $2,659 $1,329 2011 (S) Automobile $2,753   CCA Automobile $2,576   Makeup/Hair $2,431 $1,251   Entertainment $2,618 $870   Research and Development $2,387 $148   Travel $13,158 $695   Wardrobe $6,414 $3,222 [11]          It should be noted that: –   The 2009 advertising expenses consist of purchases of gifts to the cast and crew of productions Mr. ... King COUNSEL OF RECORD:     For the Appellants:       Firm:     For the Respondent: Nathalie G. ... However, in categories where the differences matter to the outcome, the numbers are clear. [3] See Exhibits A-9 and A-10. [4] 2007 TCC 191, at the bottom of page 8 of the PDF version of the transcript of the reasons for judgment on CanLII, affirmed by the Federal Court of Appeal, 2009 FCA 314. ...

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