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TCC

Bédard v. The Queen, 2016 TCC 179 (Informal Procedure)

“Patrick Boyle” Boyle J.         Translation certified true on this 7th day of December 2016.         ... The normal reassessment periods expired in 2005. The notices of reassessment were issued in 2009. ...
TCC

Abenaim v. The Queen, 2017 TCC 223

Abenaim’s salary and commission remained stable: [6] Taxation year Salary and commission (T4) 2000 $327,671 2001 $279,661 2002 $229,057 2003 $262,619 2004 $239,971 2005 $224,314 2006 $137,270 for 7 months [42]   Following his dismissal, Mr. ... Fournier’s testimony [71]   Mr. Fournier represented Mr. Abenaim during the second dispute. [72]   Mr. ... Drouin Deputy Attorney General of Canada Ottawa, Canada     [1]   See section 241 of the Canada Business Corporations Act, RSC 1985, c.  ...
FCTD

Lambert v. Canada (Attorney General), 2015 FC 1236

A.                 Recommendation Report (Lambert) [13]            Unlike Mr. ... B.                  Recommendation Report (Sobey) [15]            Mr. ... II.                 Issues [18]            The issues are: A.     Is the Decision to deny the Applicants’ request for taxpayer relief reasonable?                                 ...
FCTD

Gordillo v. Canada (Attorney General), 2019 FC 950

The Commissioner determined in a letter dated April 5, 2018, that the requirements of subsection 33(1) of the Public Servants Disclosure Protection Act, SC 2005, c 46 [the Act] had not been met and it was not in the public interest to commence an investigation into alleged wrongdoings at the Canadian Embassy in Mexico [the “Embassy”]. ...   39. If some other documents were reviewed from among the remaining sourced footnotes, there is no transparency in terms of which documents were reviewed and which were not reviewed. ….. ... DATED: July 18, 2019   APPEARANCES: Yavar Hameed Shin Imai   For The Applicants   Patrick Bendin   For The Respondent   SOLICITORS OF RECORD: Hameed Law Barristers and Solicitors Ottawa, Ontario   For The Applicants   Attorney General of Canada Ottawa, Ontario   For The Respondent     ...
FCTD

Ghazi v. Canada (National Revenue), 2019 FC 860

Ghazi. (3)   Can the Federal Court grant the relief sought? (a)   Mandamus [49]   The Respondent submits that the Applicant does not meet the seven-part test to grant a mandamus: 1.   ... D.   Final consideration [61]   After the hearing of this motion, counsel for Mr.  ... V.   CONCLUSION [63]   In summary, the Respondent’s motion is granted and the application for judicial review is struck as: 1.   ...
TCC

Huntly Investments Limited v. The Queen, 2017 TCC 255

REASONS FOR JUDGMENT Paris J. [1]               Under subsection 125(1) of the Income Tax Act (the Act ”), a Canadian‑controlled private corporation is entitled to claim the small business deduction in relation to active business income earned in Canada. ... The Queen, 2005 FCA 185 at paras 14-15: In my view, the conclusion by Muldoon J. in Hughes and Co., supra, at page 6517, that the term “full-time” employment in the definition of “specified investment business” is used in contra-distinction with “part-time” employment, is correct. ... Drouin Deputy Attorney General of Canada  Ottawa, Canada     ...
FCTD

Schillaci v. Canada (National Revenue), 2021 FC 27

III.   Issues and Standards of Review [16]   As elaborated through Mr. ... No standard of review is therefore applicable. [18]   On the second issue, the parties agree that this Court’s review of the substance of the Minister’s refusal to exercise discretion should be undertaken on the reasonableness standard: Vavilov at paras 16–17, 23–25; Lanno v Canada (Customs & Revenue Agency), 2005 FCA 153 at para 7; Canada Revenue Agency v Telfer, 2009 FCA 23 at paras 2, 24. ... DATED: January 8, 2021   APPEARANCES: Roberto Cucci   For The Applicant   Kevin Hong   For The Respondent   SOLICITORS OF RECORD: Roberto Cucci Barrister and Solicitor Toronto, Ontario   For The Applicant   Attorney General of Canada Toronto, Ontario   For The Respondent     ...
FCTD

Toney v. Canada (Public Safety and Emergency Preparedness), 2019 FC 1018

II.   Decision under review [16]   The Decision is dated August 2, 2018. ... VII.   Conclusion [58]   The application is allowed. [59]   No question for certification was proposed by the parties and none arises in this case.   ... DATED: July 30, 2019   APPEARANCES: Richard Wazana   For The ApplicantS Nicole Rahaman   For The Respondent SOLICITORS OF RECORD: WAZANALAW Barristers & Solicitors Toronto, Ontario   For The ApplicantS Attorney General of Canada Toronto, Ontario   For The Respondent   ...
FCA

Devon Canada Corporation v. Canada, 2015 FCA 214

HER MAJESTY THE QUEEN     AND DOCKETS: A-390-14 A-391-14     STYLE OF CAUSE: HER MAJESTY THE QUEEN v. DEVON CANADA CORPORATION     PLACE OF HEARING: Ottawa, Ontario   DATE OF HEARING: June 9, 2015   REASONS FOR JUDGMENT BY: WEBB J.A.   ... Pentney Deputy Attorney General of Canada   For The Appellant her majesty the queen   Osler, Hoskin & Harcourt LLP Toronto, Ontario   For The Respondent devon canada corporation     ...
FCTD

Canada v. Callidus Capital Corporation, 2015 FC 977

Cheese Factory is or was the registered owner of properties municipally known as 680 Bishop Street, Cambridge, Ontario (the Bishop Property ”) and 181 Pinebush Road, Cambridge, Ontario (the Pinebush Property ”). 2.         ... Pursuant to the terms of the Forbearance Agreement and a Blocked Accounts Agreement dated November 9, 2011 (the Blocked Accounts Agreement ”), Cheese Factory also agreed to open blocked accounts (the Blocked Accounts ”) at Royal Bank of Canada (“ RBC ”) and to deposit all funds received from all sources into the blocked accounts. 13.       ... FEDERAL COURT SOLICITORS OF RECORD DOCKET: T-1940-13   STYLE OF CAUSE: HMTQ V CALLIDUS CAPITAL CORPORATION   PLACE OF HEARING: toronto, ontario   DATE OF HEARING: april 8, 2015 ORDER AND reasons: MCVEIGH J.   ...

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