Search - 2005年 抽纸品牌 质量排名

II.   Context [5]   The Applicant is a family-owned business that was founded in 1994. ... IV.   Analysis A.   Should mandamus issue to force the Respondent to pay the net tax refunds claimed by the Applicant? ... The Applicant points to the accepted approach to statutory interpretation set out by the Supreme Court of Canada, which requires a textual, contextual, and purposive analysis to determine the meaning of subsection 229(1) in a manner that is harmonious with the Act as a whole (Canada Trustco Mortgage Co v Canada, 2005 SCC 54 at para 10 [Canada Trustco] and Copthorne Holdings Ltd v Canada, 2011 SCC 63 at para 70). ...

THE LAW (a) The Statute [27] The relevant excerpted provisions of the Income Tax Act, RSC 1985, c.1, as amended (the “ Act ”) provide as follows: 1) PART I – INCOME TAX 2) DIVISION B – COMPUTATION OF INCOME Section 91(1) Amounts to be included in respect of share of foreign affiliate 91 (1) In computing the income […] of a taxpayer resident in Canada, there shall be included, in respect of each share owned by the taxpayer of a controlled foreign affiliate as income […] the foreign accrual property income of any controlled foreign affiliate […]. ... HAM: […] let's look at 95(2)(b)(i)(A)(I) […] when we break it down it starts off with the provision of services […] […] So, we have two conditions there, services, services by a foreign affiliate. ... That's the first deeming part, Your Honour. […] […] So, I'm going to just kind of skip everything between that comma and the next comma. […] MS. ...

Likelihood of Success [3]   Mr. Sweetman claimed donation tax credits in his 2004, 2005, 2006 and 2007 tax years in relation to almost $3,000,000 in gifts he claims to have made through a promoted program known as the Global Learning Gifting Initiative (“GLGI”). ... Drouin Deputy Attorney General of Canada Ottawa, Canada   [1]   2015 TCC 244. [2]   Mariano at para. 146. [3]   Written decisions were issued in Tudora v. ... The Queen, 2019 TCC 260. [4]   2017 FCA 19. [5]   Mariano v. The Queen, 2016 TCC 161. ...

Pierre, Articling Student   JUDGMENT   In accordance with the attached reasons for judgment:     The appeal from a reassessment made under the Income Tax Act in respect of the Appellant’s 2013 taxation year is dismissed. ... In 2005, he registered in a PhD program at Cairo University and completed some of the course work towards that PhD before Egypt selected him to come to Canada. ... [16]   Dr. Ismail registered for the PhD program at Cairo University in 2005 and testified he remained registered as a PhD student in Egypt throughout 2013. ...

LEBLANC J.A.   Date: 20211115 Dockets: A-260-20 (Lead) A-261-20 A-262-20 Citation: 2021 FCA 218 CORAM: WEBB J.A. ... Background [5] In 2005, Patricia Baker contributed $210 to settle the “Desire2Learn Employee Stock Trust” (the D2L Employee Trust). ... François Daigle Deputy Attorney General of Canada For The Respondent   ...

(m)- for any device or equipment for use by the patient that             (i)     is of a prescribed kind,             (ii)    is prescribed by a medical practitioner,             (iii) is not described in any other paragraph of this subsection, and             (iv) meets such conditions as may be prescribed as to its use or the reason for its acquisition, to the extent that the amount so paid does not exceed the amount, if any, prescribed in respect of the device or equipment; Section 5700 of the Income Tax Regulations reads in part 5700.    ... (b)      Were they devices designed to assist an individual in walking? ... The Queen, [1994] 4 C.T.C. 2005 in which Rowe, J. of this Court dismissed the appeal of a wife who attempted to deduct as a medical expense the cost of purchasing and installing a hot tub which was prescribed by her husband's arthritis specialist. ...

“Gabrielle St-Hilaire” St-Hilaire J.   Citation: 2024 TCC 30 Date: 20240328 Docket: 2021-2037(IT)G BETWEEN: LARK INVESTMENTS INC., Appellant, and HIS MAJESTY THE KING, Respondent.   ... “Gabrielle St-Hilaire” St-Hilaire J.   SCHEDULE A   Further Amended Reply – Paragraph 67   67. ... Bureau 2500, 1, Place Ville Marie Montréal (Québec) H3B 1R1   For the Respondent: Shalene Curtis-Micallef Deputy Attorney General of Canada Ottawa, Canada   ...

Scott Bodie” Bodie J.   Citation: 2025 TCC 70 Date: 20250506 Docket: 2021-1465(GST)G BETWEEN: MEDSLEEP INC., Appellant, and HIS MAJESTY THE KING, Respondent.   ... The transfer is a capital transaction at the outset — at the time the agreement is entered into. ... Mr Tsambourlianos, under these agreements, all four types, are — in-in MedSleep’s opinion is — are Sleep Physicians paying for something supplied by — A. ...

II.   Background [3]   The Applicant, Nordette Loraine Fray, is a 34-year-old citizen of Jamaica. ... III.   Decision Under Review [9]   In the Decision dated November 9, 2018, the Officer found that Ms. ... While the adequacy of reasons is not a stand-alone basis for quashing a decision, a decision can be unreasonable if it does not disclose how the decision-maker arrived at his or her conclusion (see, e.g., Chakanyuka v Canada (Citizenship and Immigration), 2017 FC 313 at paras 9-10, relying on Adu v Canada (Citizenship and Immigration), 2005 FC 565 at para 14). [16]   I recognize that the Decision does not expressly set out an analysis of the evidence explaining how the Officer arrived at the resulting conclusion. ...

I think any doubt arising from the difficulties of the language should be resolved in favour of the claimant. … [11]         Similarly, Iacobucci J. in Rizzo & Rizzo Shoes Ltd. ... It seems to me that, by limiting its analysis to the plain meaning of ss. 40 and 40a of the ESA, the Court of Appeal adopted an overly restrictive approach that is inconsistent with the scheme of the Act. [12]         The aforementioned statements have been referenced by this Court in several decisions relating to the determination of insurable hours under this Act (MacKenzie, at paragraphs 43 to 44; Sutton v MNR, 2005 TCC 125, [2005] TCJ No. 257, at paragraph 17; Kuffner v MNR, [2001] TCJ No. 23, at paragraph 15; and Bylow v MNR, [2000] TCJ No. 187, at paragraph 8). ... Pentney Deputy Attorney General of Canada Ottawa, Canada     ...