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Decision summary

Bank Voor Handel En Scheepvaart v. Slatford, [1951] 2 All E.R. 779 -- summary under Ownership

.'s Claim [1927] BY Int'l L156, at 162: "'... The decisions of principle of the highest courts of most countries continue to hold that neither the shareholders nor their creditors have any right to the corporate assets other than to receive, during the existence of the company, a share of the profits, the distribution of which has been decided by a majority of the shareholders, and, after its winding-up, a proportional share of the assets'. ...
Decision summary

Bank Voor Handel En Scheepvaart v. Slatford, [1951] 2 All E.R. 779 -- summary under Personality

.'s Claim [1927] BY Int'l L156, at 162: "'... The decisions of principle of the highest courts of most countries continue to hold that neither the shareholders nor their creditors have any right to the corporate assets other than to receive, during the existence of the company, a share of the profits, the distribution of which has been decided by a majority of the shareholders, and, after its winding-up, a proportional share of the assets'. ...
Decision summary

Blais v. MNR, 92 DTC 1497 (TCC) -- summary under Paragraph 56(1)(b)

In finding that the alimentary allowance was not "paid" by him for purposes of s. 60(b), and was not "received" by her for purposes of s. 56(1)(b), Garon J. stated (p. 1499): "... ...
Decision summary

Blais v. MNR, 92 DTC 1497 (TCC) -- summary under Paragraph 60(b)

In finding that the alimentary allowance was not "paid" by him for purposes of s. 60(b), and was not "received" by her for purposes of s. 56(1)(b), Garon J. stated (p. 1499): "... ...
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. ...
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): "... ...
Decision summary

Netupsky v. The Queen, 2003 DTC 5324 (FCTD) -- summary under Subsection 220(3.1)

The Queen, 2003 DTC 5324 (FCTD)-- summary under Subsection 220(3.1) Summary Under Tax Topics- Income Tax Act- Section 220- Subsection 220(3.1) The taxpayer's application for relief based on his being " de facto bankrupt" was rejected by a CCRA officer who did not have appropriate delegated authority. ...
Decision summary

Del Grande v. The Queen, 93 DTC 133 (TCC) -- summary under Specific v. General Provisions

General Provisions In indicating that to the extent that there is any overlap between ss.15(1)(c) and 7(1), the latter provision should prevail, Bowman TCJ. stated (p. 138): "... where a choice must be made between two taxing provisions that might conceivably apply to require an inclusion in income, a specific provision should prevail over a general one, on the footing that Parliament must be taken to have intended that the specific provisions would regulate the particular type of transaction. ...
Decision summary

Willingale v. International Commercial Bank Ltd. (1978), 52 TC 242 (HL) -- summary under Accounting Principles

International Commercial Bank Ltd. (1978), 52 TC 242 (HL)-- summary under Accounting Principles Summary Under Tax Topics- Income Tax Act- Section 9- Accounting Principles In finding that discounts on bills should be taken into income on the disposition of the bills rather than on a straight-line basis, as was done for accounting purposes, Lord Fraser stated (p. 272): "... the Crown, relied on the general rule that the principles of commercial accounting should normally prevail. ...
Decision summary

Alberta v ENMAX Energy Corporation, 2018 ABCA 147 -- summary under Hansard, explanatory notes, etc.

Summary Under Tax Topics- Statutory Interpretation- Hansard, explanatory notes, etc. purpose inferred in part from Legislative Assembly statement of Minister The Court inferred from a response (quoted at para. 21) to an MLA question given by the Minister of Energy in the Alberta legislature- that there was an intention to create “level playing field” between municipally-owned power companies and taxable competitors that it was contrary to the purpose of a legislative rule requiring such otherwise-exempt companies to make payments in lieu of taxes, to be able to “shelter” their earnings by paying junk-bond interest rates on financing from their exempt parents. ...

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