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FCA (summary)
Hedges v. Canada, 2016 FCA 19 -- summary under Section 2
. … While holding an ATP may exempt one from the application of the criminal law, it is not an “exemption” as contemplated by fiscal legislation…. ...
FCTD (summary)
ConocoPhillips Canada Resources Corp. v. Canada (National Revenue), 2016 DTC 5016 [at 6588], 2016 FC 98, 2017 FCA 243 rev'd -- summary under Subsection 165(1)
. … Moreover, subsection 220(2.1) specifically enables the Minister to request a document that has been waived. ...
FCA (summary)
Jarrold v. Canada, 2010 FCA 278 -- summary under Subsection 323(3)
A submission of the appellant that he should not be liable for the unremitted GST of the company because the Minister took too long to assess (over 10 years), was rejected as being inconsistent with Addison & Leyen. ...
TCC (summary)
Marra v. The Queen, 2016 DTC 1028 [at 2696], 2016 TCC 24 -- summary under Subsection 323(5)
Rip J found that in these circumstances it was sufficient for her to hand a written resignation to the lawyer who had acted for the company, even though he never got around to filing the resignation in the minute book (or notifying the company's branch of the resignation, as required) – so that from the time of giving him the resignation, the two year period for barring CRA from making a derivative assessment under ITA s. 227.1(4) and ETA s. 323(5) started running. ...
FCTD (summary)
Rothmans of Pall Mall Canada Ltd. v. MNR, [1976] CTC 332, [1976] 2 FC 500, 10 NR 153 (FCA) -- summary under Cigarette
Two of the four main Canadian cigarette companies (MacDonald, and Benson & Hedges) proposed to introduce a cigarette having an overall length including the filter tip of over four inches, but with the tobacco portion less than four inches. ...
TCC (summary)
Chaudhry v. The Queen, 2016 DTC 1030 [at 2721], 2016 TCC 28 (Informal Procedure) -- summary under Evidence
. … Further, the appellant’s agent did not assert that two differing versions of the Act required reconciliation under subsection 31(2) of the LRCA. ...
FCA (summary)
AgraCity Ltd v. Canada, 2016 DTC 5006 [at 6525], 2015 FCA 288 -- summary under Section 53
. … Because each taxpayer is assessed (or reassessed) separately, this can result in inconsistent assessments (Peterson v. ...
FCA (summary)
AgraCity Ltd v. Canada, 2016 DTC 5006 [at 6525], 2015 FCA 288 -- summary under Subsection 152(1)
Canada, 2016 DTC 5006 [at 6525], 2015 FCA 288-- summary under Subsection 152(1) Summary Under Tax Topics- Income Tax Act- Section 152- Subsection 152(1) inconsistent assessments of related taxpayers A Barbados corporation reported substantial profits from the sale of a herbicide to Canadian farmers, and deducted amounts paid to a non-arm’s length Canadian corporation (AgraCity – which was the taxpayer in the case) as service fees. ...
TCC (summary)
Crooks v. The Queen, 2016 TCC 52 (Informal Procedure) -- summary under Subsection 262(3)
Richards’s guarantee – and as not resulting in any interest in the condo also being supplied by the builder to Ms. ...
FCTD (summary)
Muir v. Canada (National Revenue), 2016 FC 362 -- summary under Subsection 220(3.1)
. … In any event, I agree with the CRA’s interpretation that financial hardship for an individual is financial suffering or lack of what is needed for basic living requirements, such as food, clothing, shelter and reasonable nonessentials. ...