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EC decision

Home Provisioners (Manitoba) Ltd. v. MNR, 58 DTC 1183, [1958] CTC 334, [1958] CTC 333 (Ex Ct)

“EXECUTED by the undersigned on the day of. l 19 $248,375.72, from which a sum of $99,587.92 was deducted as “deferred gross profit on instalment contracts’’. ...
TCC

Grand Toys Ltd. v. MNR, 90 DTC 1059, [1990] 1 CTC 2165 (TCC)

Counsel for the respondent referred me also to my own words in D & B Oilfield Contracting Ltd. v. ...
FCA

Canada v. Pardee Equipment Limited, 99 DTC 5012, [1999] 1 CTC 101 (FCA)

It deals primarily in lines of equipment manufactured by Deere & Co., an American corporation. ...
TCC

Husel Estate v. The Queen, 94 DTC 1765, [1995] 1 CTC 2298 (TCC)

Where any property of a taxpayer who was resident in Canada immediately before his death that is a property to which paragraphs (5)(a) and (c), or [...], would otherwise apply has, on or after his death and as a consequence thereof been transferred or distributed to (a) his spouse who was resident in Canada immediately before the taxpayer’s death, or if it can be shown, within the period ending 36 months after the death of the taxpayer...that the property has become vested indefeasibly in the spouse...the following rules apply: (c) paragraphs (5)(a) to (d) are not applicable to the property; (d) the taxpayer shall be deemed to have disposed of the property immediately before his death and to have received proceeds of disposition therefor equal to, (ii)...the adjusted cost base to the taxpayer of the property immediately before his death, and the spouse...shall be deemed to have acquired the property for an amount equal to those proceeds; 70(6.2) Election. ...
FCTD

Richard v. MNR, 88 DTC 6239, [1988] 1 CTC 388 (FCTD)

Justice Dubé in the case of Director of Investigation & Research: the Competition Act, R.S.C. 1970, Chap. ...
TCC

Balmoral Investments Ltd. v. The Queen, 97 DTC 802, [1997] 1 CTC 2372 (TCC)

. “income of the corporation for the year from an active business” means the total of... ...
FCTD

Greiner v. The Queen, 81 DTC 5371, [1981] CTC 477 (FCTD), aff'd 84 DTC 6073, [1984] CTC 92 (FCA)

I cannot accept that evidence nor can I regard, as I was invited to do, the total amount of payment as representing compensation in lieu of damages. dent, this would produce a total amount of some $243,750 (ie, $75,000 39 + 12 $243,750. ...
TCC

Stone Container (Canada) Inc. v. R., 98 DTC 1508, [1998] 3 CTC 2150 (TCC)

Ct.) at 198per Thorson, P. 13 ' If 1 were to vacate this third reassessment, then the second reassessment would come into force. ...
FCA

Human Life International in Canada Inc. v. Minister of National Revenue, 98 DTC 6196, [1998] 3 CTC 126 (FCA)

Attorney General [11] where it was said that trusts for political purposes: include, inter alia, trusts of which a direct and principal purpose is either (I) to further the interests of a particular political party; or (ii) to procure changes in the laws of this country; or (iii) to procure changes in the laws of a foreign country; or (iv) to procure a reversal of government policy or of particular decisions of governmental authorities in this country; or (v) to procure a reversal of government policy or of particular decisions of governmental authorities in a foreign country. ...
FCTD

Mendels v. The Queen, 78 DTC 6267, [1978] CTC 404 (FCTD)

As I appreciate the principle with respect to a finding of sham enunciated by Mr Justice Heald speaking for the Court of Appeal in the Leon case (supra) it was that while a company may be incorporated for the purposes which it was intended to be incorporated and pursued those purposes and therefore would not be a sham within the meaning of that word as laid down by Lord Diplock in Snook v London & West Riding Investments Ltd ([1967] 1 All ER 518 at 528) nevertheless such a management company may become a sham company if the agreement or transaction with that company lacks a bona fide purpose therefor. ...

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