Search - 2002年 抽纸品牌 质量排名

Signed at Ottawa, Canada, this 19 th day of November, 2015.   “David Graham” Graham J.   ... Magee, Principles of Canadian Income Tax Law (4th ed. 2002), at p. 563. ... Pentney Deputy Attorney General of Canada Ottawa, Canada     [1]           2008 FCA 89 at para 17 [2]             2013 TCC 60 [3]           2009 TCC 219 [4]           I also note in passing that the phrase “at the time of transfer” was not included in the third branch of the third test in Livingston. ...

The Appellant did not have unreported income; and 2.   The Appellant is not liable for penalties under subsection 163(2) of the Act.   ... The SuperWok restaurants had to be closed, the first one in 2000 and the second one in 2002. [13]   In 2003, Mr. ... The Tong children worked in the restaurant; 5.   Cash from sales at the restaurant was not deposited to the BMO bank account; 6.   ...

(Toronto: Irwin Law, 2016) (“Sullivan”) at page 43. [33] [1957] S.C.R. 167 (“ Consolidated Glass ”). [34] [1968] 2 Ex CR 44, [1968] CTC 65, 68 DTC 5045 (“ D.W.S. ... Minister of National Revenue, [1955] S.C.R. 745 (“ Eli Lilly ”), Tip Top Tailors Ltd. v. ... Canadian Pacific Limited, [2002] 2 CTC 197, 2002 DTC 6742 (FCA) at paragraph 23 and Saskferco Products ULC v. ...

Sweet & Maxwell, 27th Ed. 1994, paragraphs 3-020 and 3-021.) Their alleged deal was a nullity. 3. ... Per: “ L. Shapiro” GLOBAL COMMUNICATIONS LIMITED Per: “ J.H. Burgis ” V.P. ... Alberta (Minister of Energy & Natural Resources) (1986), 45 Alta. ...

The Queen, 2021 TCC 13 Docket: 2016-4417(IT)G BETWEEN: ADINA GOLDMAN, Appellant, and HER MAJESTY THE QUEEN, Respondent.   ... Drouin Deputy Attorney General of Canada Ottawa, Canada   [1] Charkaoui v. ... Rose, 2009 FCA 93 at para. 28. [15] 2008 FCA 89 (leave to appeal denied, 2008 CarswellNat 3336). [16] 2002 FCA 23, at para. 8. [17] 2007 TCC 303. [18] The appeal was allowed on separate grounds. ...

   [10]     The following people testified for the Respondent: Ms. Isabelle Mercier; Ms. ... (Exhibit I-15, Tab 8): Year Date of receipt Receipt No Amount of receipt 1990 Dec.18, 1990 1414 $5,000       1991 Feb. 20, 1991 1496 $200       May 29, 1991 1735 $7,000       July 10, 1991 1739 $10,000       Dec.15, 1991 1855 $3,500       1992 June 7, 1992 2359 $3,500       June 20, 1992 2364 $5,500       Dec. 6, 1992 2541 $3,500       1993 Nov. 9, 1993 2867 $6,000       Dec.13, 1993 0006 $3,500       1994 June 30, 1994 0936 $6,500       Dec. 26, 1994 0852 $5,000       1995 June 25, 1995 1301 $6,000       [77]      Mr. ... Jarvis, [2002] 3 S.C.R. 757, 2002 SCC 73. He also cites more specifically, the decisions in Ruby v. ...

He joined the Appellant in 2002 and became President and Chief Technology officer in 2004. [13] Mr. ... The Queen, 2001 FCA 393, 2002 DTC 6740, at paragraph 17, as follows: 1. ... The calculation for the 2010 Taxation Year is as follows:     Filed by Taxpayer Assessed by the CRA         Total SR&ED Expenditures   $587,005 $171,979 Add:       Prescribed Proxy Amount 65% $365,003 $111,786 Deduct       Government Assistance- OITC   $88,705 $11,179 Government Assistance- IRAP   $65,261 $171,979         Qualified Expenditures for ITC   $798,342 $100,607         ITC 35% [18] $279,420 $35,212   [218] The calculation for the 2011 Taxation Year is as follows:     Filed by Taxpayer Assessed by the CRA         Total SR&ED Expenditures   $418,890 $120,635 Add:       Prescribed Proxy Amount 65% $272,279 $78,413 Deduct       Government Assistance- OITC   $68,834 $16,945 Government Assistance- IRAP   $6,829 $29,598         Qualified Expenditures for ITC   $615,506 $152,505         ITC 35% $215,567 $53,377   [219] The Appellant did not provide the details of its calculation of the amounts claimed on its tax returns. ...

THE QUEEN   PLACE OF HEARING: Toronto, Ontario   DATE OF HEARING: July 11, 2016   DATES OF APPELLANT’S SUBMISSIONS: August 10 and September 26, 2016   DATE OF RESPONDENT’S SUBMISSIONS: September 9, 2016   REASONS FOR JUDGMENT BY: The Honourable Justice Patrick Boyle   DATE OF JUDGMENT: January 31, 2017   APPEARANCES:   Counsel for the Appellant: Al Tharani Counsel for the Respondent: Eric Myles COUNSEL OF RECORD:     For the Appellant: Al Tharani   Firm: Barrett Tax Law Vaughan, Ontario   For the Respondent: William F. Pentney Deputy Attorney General of Canada Ottawa, Canada     [1] [1998] T.C.J. ... No. 1890 (QL). [4] 2001 FCA 393. [5] 2011 FCA 355. [6] 2016 FCA 152. [7] 2002 FCA 328. [8] According to Ms.  ...

The King, 2024 TCC 82 Docket: 2018-4865(IT)G BETWEEN: HELEN SCHONBERGER, Appellant, and HIS MAJESTY THE KING, Respondent.   ... Gagnon” Gagnon J.   Docket: 2018-4866(IT)G BETWEEN: TOMMY SCHONBERGER, Appellant, and HIS MAJESTY THE KING, Respondent.   ... “J M Gagnon” Gagnon J.   CITATION: 2024 TCC 82 COURT FILES NO.: 2018-4865(IT)G 2018-4866(IT)G STYLE OF CAUSE: HELEN SCHONBERGER v. ...

A.         Yes. Q.         And who did the general partner select? A.         ... A.        Yes there were. Q.         Do you know how many? A.         ... Canadian Pacific Limited, 2002 DTC 6742: 54.        However, the transactions at issue cannot first be collapsed into a share purchase either on an economic substance analysis or on the basis of subsection 245(5) of the Act, as a prelude to applying the GAAR. ...