Search - 辐射监测仪 校准

Osler, Hoskin & Harcourt, states that in connection with the issue of costs "in all circumstances the parties ought to bear their own costs. ... Grace & Co. et al. (1983), 77 C.P.R. (2d) 274 (F.C.T.D.) at page 276). ...

Rip” J.T.C.C. [1]           Toby Perry appealed his income tax assessments for 1989 and 1990 on the same basis as Stanley Kelley, Clare Smith and Dale Smith. ... His appeals are therefore dismissed with costs. [2]           In his submission, respondent’s counsel asked that no weight be given to Mr. ...

In the draft contract – Exhibit R-1- Blaney had intended to limit Butterfield to providing services exclusively to SDC during the term of the contract but that provision did not make it into the signed contract- Exhibit A-1. ... Pursuant to the paragraph 9(3) of the Tax Court of Canada Rules (E.I.) an intervener: "... may state in the notice of intervention that the intervener intends to rely on the reasons set out in the notice of appeal received by the intervener or the reasons set out in the notice of intervention of another intervener. ...

Subsection 280(1) of the Excise Tax Act (“the Act ”) provides: “280. (1) Subject to this section and section 281, where a person fails to remit or pay an amount to the Receiver General when required under this Part, the person shall pay on the amount not remitted or paid (a) a penalty of 6% per year, and (b) interest at the prescribed rate, computed for the period beginning on the first day following the day on or before which the amount was required to be remitted or paid and ending on the day the amount is remitted or paid.” [5] The onus is on the appellant to show that the reassessment is in error. ... It is sufficient for present purposes to reproduce these portions of B-074: “ Introduction This bulletin explains the guidelines for the reduction of penalty and interest in ‘wash transaction’ situations. ...

Consequently, after applying unsuccessfully before Reed, J. to strike out the statement of claim as an abuse of the Court's process (the plaintiff had filed a concurrent appeal in the Tax Court of Canada in respect of the same assessment, but at the motion to strike agreed to discontinue the Tax Court proceeding) the Minister filed a defence in which it was conceded that the taxable capital gain of $56,000 had been wrongly included in the plaintiff's income for 1983, and consented to judgment ” to the limited extent that the sum of $56,000 be deleted from the plaintiff's income for the year" but that the plaintiff's action be dismissed in all other respects. ... The law on which the case is based must be a " law of Canada" as the phrase is used in section 101 of the Constitution Act, 1867. ...

Paterson & Associates Ltd. ("Associates") who owned 50 per cent and Richard Gillard who owned 25 per cent. ... Paterson & Associates Ltd. ("Associates"). Paterson first participated in real estate ventures with Giuliani and Gillard in 1979 when they purchased an apartment building of approximately 100 units in Ottawa. ...

Cominco relies heavily on the “general rule" enunciated in the first sentence. [2] Ontario relies on the phrase in the second sentence "An amending enactment may provide that it shall be deemed to have come into force on a date prior to its enactment” — it says that subsection 30(24) does precisely this. ... Comi neo asserts that when read together, those provisions, especially paragraph 73(7)(b) of the Ontario Act and section 111 of the federal Act ("which was also applicable for purposes of the [Ontario] Act" — see Special Case, paragraph 3), establish that the reason for the extended period of reassessment in both Acts is that section 111 provides the taxpayer with the benefit of an extended period of loss carryover. [3] In other words, there is a nexus or a mutuality between the new provisions—the taxpayer has the advantage of a new and additional loss carryover period and the two governments are given a new and additional reassessment period. ...

The second farm, “ Rockhurst” comprised 166 acres and was acquired in the name of a company called Rockhurst Farms Ltd., the shares of which were owned by the appellant's wife and his children. ... But he is a self-described workaholic and there is no doubt that his “ major preoccupation”, the term used in Moldowan, was farming. ...

Tarantino tax returns of the appellant for the 1978-81 years and he agreed the business of Universal was described as "Mortgage Broker and Real Estate” or “ Broker, Sales, Real Estate" or "Management Consultant and Real Estate Broker”. ... Evidence of transactions of the sale and purchase of real estate by an appellant after the years under review in an appeal is admissible: Osler Hammond & Nanton Ltd. v. ...

& Mrs. Higgins instructed a certified general accountant to travel as soon as possible to Sparwood to conduct an audit. ... To extrapolate, I find the following as fact: — By February 20, 1987 the appellant was generally aware of operational shortages and the probability of non-remittances tax withholdings; —Shortly thereafter he received the request to act as director; —On February 22 he and the Higginses authorized an accounting review which commenced March 23; —He signed the consent dated February 4 around March 23; —He received the accountant's information concerning the remittance failures on March 31 and then told the accountant to go back for another check to determine where the money may have gone; —By April 15 the accountant had corresponded with Revenue Canada concerning the non-remittances; and —The appellant resigned April 16 and attended an April 29 meeting in the capacity of an investor. ...