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Decision summary

Mac's Convenience Stores Inc. v. A.G. of Canada, 2015 QCCA 837 -- summary under Paragraph (a)

See summary under General Concepts Rectification. ...
TCC (summary)

Shaver v. The Queen, 2003 DTC 2112, 2004 TCC 10 -- summary under Subsection 20(10)

Lamarre J. stated (at p. 2119): "... The seminars in question herein can very well be defined as formal meetings of members of an organization (Amway) that are held for business purposes and that result in the acquisition of knowledge by those attending them. ...
TCC (summary)

Dubawn Holdings Inc. v. The Queen, 94 DTC 1252, [1994] 1 CTC 2527 (TCC) -- summary under Paragraph 12(1)(e)

Mogan TCJ. stated (p. 1257): "... if a reserve is in fact claimed and allowed in a particular taxation year, the legality of the allowance is not material and the amount that was in fact deducted must be included in computing the income for the immediately following year". ...
FCA (summary)

Harvey C. Smith Drugs Ltd. v. The Queen, [1995] 1 C.T.C. 143 (FCA) -- summary under Interpretation Bulletins, etc.

After noting that paragraph 41 of IT-145R, dated June 19, 1981, was contrary to the taxpayer's position, Desjardin J. noted (p. 9): "... ...
FCTD (summary)

Lipsey v. MNR, 85 DTC 5080, [1984] CTC 675 (FCTD) -- summary under Subsection 152(1)

., doubted that a judge would ever be in a position to direct the issuance of a notice of assessment because "to issue mandamus the Court must be satisfied that all the conditions have been met for the exercise of the power, and that in the circumstances the official in question has no discretionary power to delay or to refuse taking the step which is sought to be ordered by mandamus ". ...
Decision summary

Argus Holdings Ltd. v. The Queen, 2001 DTC 6681 (FCA) -- summary under Evidence

The Queen, 2001 DTC 6681 (FCA)-- summary under Evidence Summary Under Tax Topics- General Concepts- Evidence treatment not governed by accounting description Before finding that the taxpayer, in effect, had deducted reserves under s. 20(1)(m) with respect to initiation fees which, for accounting purposes, it had brought into income over the ten years following receipt on a straight-line basis, McDonald J.A. stated (at p. 6683): "... ...
TCC (summary)

Astral Energy Ltd. v. MNR, 90 DTC 1844, [1990] 2 CTC 2422 (TCC) -- summary under Subsection 1204(1)

" the taxpayer to whom reference is made in s. 1204(1)(b), rather than referring to "... the oil and gas business, the production of it... ...
FCA (summary)

D.MNR for Customs and Excise v. Amoco Canada Petroleum Co. Ltd., 86 DTC 6008, [1986] 1 CTC 124 (FCA) -- summary under Cost of Manufacturing and Processing Capital

Pipelines that distributed liquid hydrocarbons mix to a fractionation plant accordingly were "machinery and apparatus" that were used by it " directly in the manufacture or production of goods". ...
TCC (summary)

Severinov v. The Queen, 2013 DTC 1230 [at at 1260], 2013 TCC 292 (Informal Procedure) -- summary under Paragraph 118(1)(b)

The Queen, 2013 DTC 1230 [at at 1260], 2013 TCC 292 (Informal Procedure)-- summary under Paragraph 118(1)(b) Summary Under Tax Topics- Income Tax Act- Section 118- Subsection 118(1)- Paragraph 118(1)(b) "any time in the year" "throughout the year" The taxpayer appealed the denial of Canada child tax benefits and child tax credits. ...
TCC (summary)

Mariano v. The Queen, 2015 DTC 1209 [at at 1331], 2015 TCC 244 -- summary under Ownership

See summaries under s. 118.1 total charitable gifts and s. 104(1). ...

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