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TCC (summary)

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

Furthermore, such expert erred in treating retail sales by Infosource as a relevant comparable for valuing the licences here as they essentially had been acquired on a wholesale basis so that the modest price paid to Infosource represented the licences' fair market value. ...
TCC (summary)

Kruger Incorporated v. The Queen, 2015 DTC 1127 [at at 788], 2015 TCC 119, rev'd 2016 FCA 186 -- summary under Timing

. At the end of the day, however, it falls to Parliament to enact the law, the courts to interpret the law and the CRA to enforce the law…. ...
TCC (summary)

Barejo Holdings ULC v. The Queen, 2015 DTC 1216 [at at 1405], 2015 TCC 274, aff'd on other grounds 2016 FCA 304 -- summary under Section 8.1

. the Notes themselves are expressly to be governed by and interpreted and enforced in accordance with the laws of England…. ...
TCC (summary)

Crooks v. The Queen, 2016 TCC 52 (Informal Procedure) -- summary under Recipient

Richards’ guarantee and as not resulting in any interest in the condo also being supplied by the builder to Ms. ...
TCC (summary)

Korfage v. The Queen, 2016 TCC 69 (Informal Procedure) -- summary under Subsection 261(2)

. The Minister has discretion in the application of an appropriate exchange rate…and chose to use the annual average exchange rate for 2010 of 1.0562. ...
TCC (summary)

Standard Life Assurance Company of Canada v. The Queen, 2015 TCC 138 -- summary under Subsection 147(3)

The Queen, 2015 TCC 138-- summary under Subsection 147(3) Summary Under Tax Topics- Other Legislation/Constitution- Federal- Tax Court of Canada Rules (General Procedure)- Section 147- Subsection 147(3) Crown offer of better treatment for one of two years The Crown had made a settlement offer to the taxpayer under which the taxpayer would conced that it was not carrying on an insurance business in Bermuda in 2006, but the Crow would concede that the taxpayer was carrying on business in Bermuda in 2007 and each party would bear its own costs. ...
TCC (summary)

Poulin v. The Queen, 2016 TCC 154, briefly aff’d sub nomine Turgeon v. The Queen, 2017 FCA 103 -- summary under Subsection 84.1(1)

D’Auray J noted that this employee had no risk, and Hélie Holdco had no upside as its only assets and liabilities were the prefs and the note, both with frozen values so that Hélie Holdco essentially was just an accommodation party. ...
TCC (summary)

R. v. Golini, 2016 TCC 174 -- summary under Paragraph 20(1)(c)

. Given my finding of an offset, the rate is immaterial, however, if such a determination was necessary, I determine the interest rate should be 5.5%, being the rate suggested by the expert. ...
TCC (summary)

Rojas v. The Queen, 2016 TCC 177 (Informal Procedure) -- summary under Paragraph (r.4)

. [P]aragraph (r.4) will only apply if the service in question is supplied separately from the supply of the financial service that is referred to in any of paragraphs (a) to (i) or (l) of the definition of financial service. ...
TCC (summary)

Oldcastle Building Products Canada Inc. v. The Queen, 2016 TCC 183 -- summary under Paragraph 2900(9)(c)

. [T]he sole remuneration which was paid to Mr. Castonguay in 2010 or 2011 was not an “amount paid in addition that which is due.” ...

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