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FCTD

Ahmad v. Canada Revenue Agency, 2011 FC 954

Justice Near     BETWEEN:   NAZAR AHMAD, HAMIDUL AMEEN, PAMELA CHEUNG, HARJINDER DHESY, NORINE GOODMAN, DEBORAH HAIRE, ANDY HENDERSON, YULIA HIDIJAT, FANNY JANG, JULIAN LEBOFSKY, RICHARD MALONE, ANNA MICHIELI, CHRISTINE NG, NELLY NG, INDRAJIT ROY, SUSAN TIERNEY, CHELLIAH VENOGOPAL, SALIM VIRJI, FRANK WONG, HELEN YI, ANNA YU, AND RANDY ZURIN       Applicants   and       CANADA REVENUE AGENCY         Respondent                    AMENDED R EASONS FOR JUDGMENT AND JUDGMENT   [1]                This application for judicial review comprises 22 consolidated applications for judicial review concerning decisions made by Paul Loo in his capacity as a Decision Reviewer at the Canadian Revenue Agency (CRA).  ... As the Applicants submit, the Respondent has committed a reviewable error in failing to abide by its own procedures (Gilchrist v Canada (Treasury Board), 2005 FC 1322, 281   FTR 135 at para 13).   ...       D. G. Near Judge FEDERAL COURT   SOLICITORS OF RECORD       DOCKET:                                          T-2132-09   STYLE OF CAUSE:                          CHRISTINE NG ET AL. v. ...
SCC

Entertainment Software Association v. Society of Composers, Authors and Music Publishers of Canada, 2012 SCC 34, [2012] 2 SCR 231

Statement of Proposed Royalties to Be Collected by SOCAN for the Public Performance or the Communication to the Public by Telecommunication, in Canada, of Musical or Dramatico‑Musical Works, (2005) 139 Can. ...   [24]                           With respect, we disagree.  The 1988 amendments to the Copyright Act   found at ss. 61   to 65   of the Canada-United States Free Trade Agreement Implementation Act  , were enacted in order to give effect to Articles 2005 and 2006 of the 1987 Canada-U.S. ... He found that this particular issue was “no longer contested”. [59]                           In 2005, SOCAN modified its proposed Tariff to divide it into seven categories, each dealing with a different Internet-based activity.  ...
TCC

Corvalan v. The Queen, 2006 DTC 2907, 2006 TCC 200

.____________________________________________________________________ Appeal heard on February 17 and November 16, 2005 at Vancouver, British Columbia Before: The Honourable Justice Diane Campbell Appearances: Counsel for the Appellant: Samantha Mason Counsel for the Respondent: Bruce Senkpiel____________________________________________________________________ JUDGMENT           The appeal from the assessment made under the Income Tax Act for the 1997 taxation year is dismissed, with costs, in accordance with the attached Reasons for Judgment. ... The Evidence:           Ruben Corvalan [4]      The Appellant was born in Chile and moved to Canada in 1974. ... Note 11:    See P.W. Hogg, J.E. Magee, "Principles of Canadian Income Tax Law", 2d ed. 1997, para. 16.3(b). 21         The Tax Court judge was mindful of the difficulty of the task he was about to embark on.     ...
TCC

Mahdi v. The Queen, 2018 TCC 149

Instead, on June 18, 2010, the CRA resubmitted certain questions to Khaled for response, this time pertaining to business details and carried back business losses for 2005 through 2009 taxation years. ... The Queen, 2005 TCC 545, at paragraph 11 as: a) the magnitude of the omission in relation to the income declared, b) the opportunity the taxpayer had to detect the error, c) the taxpayer’s education and apparent intelligence, d) genuine effort to comply. 3.   ... Drouin Deputy Attorney General of Canada Ottawa, Canada     ...
TCC

Semenov v. The Queen, 2018 TCC 58

Li testified that, after her father came to Canada in 2005, he did not return to Kazakhstan. [45] When cross-examined, Ms. ... The Supreme Court of Canada has indicated that a court may properly take judicial notice of facts that are capable of immediate and accurate demonstration by resort to readily accessible sources of indisputable accuracy; see R. v Krymowski, (2005) 249 DLR (4 th) 28 (SCC); The Queen v Find, 2001 SCC 32; and The Queen v Spence, 2005 SCC 71. ... Li testified that he came to Canada on November 30, 2005 (ibid., p. 18, line 17). ...
TCC

1663255 Ontario Inc. v. M.N.R., 2011 TCC 19

., 2011 TCC 19         Citation: 2011 TCC 19 Date: January 24, 2011 Dockets: 2010-659(CPP) 2010-660(CPP BETWEEN: 1663254 ONTARIO INC., Appellant, and   THE MINISTER OF NATIONAL REVENUE, Respondent.   ... Skelton and this witness collaborating on a business arrangement in March of 2005. ... AND MINISTER OF NATIONAL REVENUE   PLACE OF HEARING:                     Ottawa, Canada   DATE OF HEARING:                       December 2, 2010   REASONS FOR JUDGMENT BY:    The Honourable Justice Diane Campbell   DATE OF ORAL JUDGMENT:         December 3, 2010   APPEARANCES:   Agent for the Appellant: Susan Tataryn Counsel for the Respondent: Serena Sial Andrew Miller   COUNSEL OF RECORD:          For the Appellant:                             Name:                                                    Firm:          For the Respondent:                    Myles J. ...
TCC

Kossow v. The Queen, 2010 TCC 279

Miller J.           Citation: 2010TCC279 Date: 20100521 Docket: 2005-1974(IT)G BETWEEN: KATHRYN KOSSOW, Appellant, and   HER MAJESTY THE QUEEN, Respondent.       ... Kossow filed her Appeal with the Tax Court of Canada in June 2005. There are well over a thousand taxpayers who made donations to the Ideas Canada Foundation in similar circumstances to Ms. ...   [4]           1983 CarswellNat 362.   [5]           2010 TCC 109.   [6]           2007 TCC 703.   ...
TCC

Prevost Car Inc. v. The Queen, 2008 TCC 231

Rip" Rip A.C.J.         Citation: 2008TCC231 Date: 20080422 Dockets: 2004-2006(IT)G 2004-4226(IT)G BETWEEN: PRÉVOST CAR INC., Appellant, and   HER MAJESTY THE QUEEN, Respondent.     ...   [86]     As a result of abuse of the treaty by conduit companies, Indonesia terminated its tax treaty with Mauritius effective January 1, 2005, thus increasing to 20 percent the withholding on the interest payments between the Parent and the Issuer. ... I also note that the Court of Appeal had regard to substance over form, as required by the law of Indonesia (paras. 18 and 24). [34]          [2005] EWHC 2103 (Ch). [35]          Ibid., para. 46. [36]          Ibid., para. 49. [37]          Supra, note 20, para. 42. [38]          Para. 43. [39]          In his report Professor van Weeghel quotes from comments by the Dutch Underminister of Finance in a Ministry of Finance memorandum to the Finance Committee of the Dutch Parliament in the 1987-1988 Parliamentary year. [40]          The Civil Code of Quebec recognizes a trust: articles 1260 to 1298. [41]          For example, s.s. 82(3), subpara. 82(1)(a)(1.1). ...
TCC

Gilbert v. The Queen, 2011 TCC 155

Translation certified true on this 9th day of May 2011         François Brunet, Revisor           Citation: 2011 TCC 155 Date: 20110310 Docket: 2008-3145(IT)G BETWEEN: JEAN-PIERRE GILBERT, Appellant, and   HER MAJESTY THE QUEEN, Respondent.   ... (j)      Under a deed of release dated November 10, 2005, the Garantie des Bâtiments Résidentiels Neufs de l’APCHQ Inc. struck from the registration of hypothecary rights, the notice of legal hypothec resulting from a judgment dated July 13, 2005, concerning the Beaubien building.   ...   [23]          For these reasons, the appeal is dismissed, with costs.           ...
FCA

Contact Lens King Inc. v. Canada, 2022 FCA 154

HIS MAJESTY THE KING   PLACE OF HEARING: Montreal, Quebec     DATE OF HEARING: June 8, 2022     REASONS FOR JUDGMENT BY: LEBLANC J.A.     ... GLEASON J.A.     DATED: SEPTEMBER 15, 2022     APPEARANCES: Guillaume Rochon Marie Arcand For the appellant CONTACT LENS KING INC.   ... Montreal, Quebec For the appellant CONTACT LENS KING INC.   A. François Daigle Deputy Attorney General of Canada Ottawa, Ontario   For the respondent HIS MAJESTY THE KING     ...

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