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FCA

Ghermezian v. Minister of National Revenue, 2023 FCA 183

ROUSSEL J.A.           BETWEEN:     NADER GHERMEZIAN, MARC VATURI, GHERFAM EQUITIES INC., PAUL GHERMEZIAN, RAPHAEL GHERMEZIAN, and JOSHUA GHERMEZIAN     Appellants (Respondents by cross-appeal)     and     THE MINISTER OF NATIONAL REVENUE     Respondent (Appellant by cross-appeal)   Heard at Toronto, Ontario, on March 1, 2023 Judgment delivered at Ottawa, Ontario, on September 1, 2023. ... ROUSSEL J.A.           BETWEEN:     NADER GHERMEZIAN, MARC VATURI, GHERFAM EQUITIES INC., PAUL GHERMEZIAN, RAPHAEL GHERMEZIAN, and JOSHUA GHERMEZIAN     Appellants (Respondents by cross-appeal)       and     THE MINISTER OF NATIONAL REVENUE     Respondent (Appellant by cross-appeal)   REASONS FOR JUDGMENT ROUSSEL J.A. ... Artistic Ideas Inc., 2005 FCA 68. [57] In Artistic Ideas, the Minister had sent a requirement for information to Artistic Ideas Inc. ...
FCA

1455257 Ontario Inc. v. Canada, 2021 FCA 142

On January 14, 2005, the Minister reassessed 661’s taxable income for its 2000 taxation year to reflect the net result of the Grosvenor Loss Determination. ... HER MAJESTY THE QUEEN     PLACE OF HEARING: Heard by online videoconference   DATE OF HEARING: June 21, 2021   REASONS FOR JUDGMENT BY: NOËL C.J.   ... LASKIN J.A.   DATED: JULY 14, 2021   APPEARANCES: Domenic Marciano Eric Torelli   For The Appellant 1455257 ONTARIO INC.   ...
TCC

Grenon v. The Queen, 2021 TCC 89

Smith Participants: Counsel for the Appellants:   Cy M. Fien Brandon Barnes Trickett Ari M. ... The normal income tax appeal- which this appeal was- is not a matter of public policy (…) or touch on constitutional principles and in the public interest (…). ... The Queen, 2016 TCC 161, para 105.   ...
FCA

Athletes 4 Athletes Foundation v. Canada (National Revenue), 2021 FCA 145

LEBLANC J.A.   Date: 20210721 Docket: A-223-19 Citation: 2021 FCA 145 CORAM: WEBB J.A. ... Canada, 2005 SCC 54, at para. 10). The role of this Court is to determine the interpretation of these provisions that was intended by Parliament. [41] The text of paragraph (d) of the definition of CAAA is as follows: Canadian amateur athletic association means an association that […] (d) has the promotion of amateur athletics in Canada on a nationwide basis as its exclusive purpose and exclusive function, and […] [42] The definition of CAAA in the Act provides that the exclusive purpose and exclusive function of a CAAA must be the promotion of amateur athletics in Canada on a nationwide basis. ... Drouin Deputy Attorney General of Canada For The Respondent   ...
TCC

Siam v. The King, 2025 TCC 69

In 2019, I opened a Bank of Montreal (“ BMO ”) account as a non-resident of Canada for tax purposes. […]. 16. The BMO Account has been garnished by the Canada Revenue Agency (“ CRA ”) since 2022 in the amount of $4,637.82 CAD. […] 22. On December 7, 2021, I received an email from my mother, Soad El Habash, informing me that the CRA had issued a Notice of Assessment for the 2016 fiscal year (the Notice ”). ...
TCC

MF Electric Incorporated v. The King, 2023 TCC 60

Further, the reassessments for the 2010, 2011 and 2012 taxation years were made beyond the normal reassessment period. [6] The following table offers a snapshot of the amounts disallowed for the taxation years under appeal and the penalties imposed: Taxation year 2010 2011 2012 2013 2015 Disallowed professional fees $28,354 $43,970 $54,715     Disallowed management fees $1,610,000     $160,000 $236,556 Penalties assessed under 163(2) $127,400     $8,800 $13,010 [7] The issues can be summarized as follows: i. ... It was to be a one-year investment with a 25% return but that never materialized. ... Brett   Firm: Burnside Law Group 202 Brownlow Avenue, Suite 400, Dartmouth, Nova Scotia B3B 1T5 For the Respondent: Shalene Curtis-Micallef Deputy Attorney General of Canada Ottawa, Canada     ...
FCA

Denso Manufacturing Canada, Inc. v. Canada (National Revenue), 2021 FCA 236

LEBLANC J.A.   Docket: A-99-20 BETWEEN: DENSO MANUFACTURING CANADA, INC. ... Ferndale Institution, 2005 SCC 82, the majority of the Supreme Court of Canada noted: 92 In the administrative context, the duty of procedural fairness generally requires that the decision-maker discloses the information he or she relied upon. ... MINISTER OF NATIONAL REVENUE   AND DOCKET: A-100-20   STYLE OF CAUSE: DENSO SALES CANADA, INC. v. ...
FCA

Levett v. Canada (Attorney General), 2022 FCA 117

LEBLANC J.A.     BETWEEN: CRAIG LEVETT and NATHALIE BENSMIHAN OFER BAAZOV and CATHY BENSMIHAN 9179-3786 QUÉBEC INC. ... THE ATTORNEY GENERAL OF CANADA and THE CANADA REVENUE AGENCY   PLACE OF HEARING: Montréal, Quebec   DATE OF HEARING: May 3, 2022   REASONS FOR JUDGMENT BY: LEBLANC J.A.   ... DE MONTIGNY J.A.   DATED: JUNE 17, 2022   APPEARANCES: François Barette Nicolas Simard   For The Appellants   Ian Demers Dominique Castagne Justine Allaire-Rondeau   For The Respondents   SOLICITORS OF RECORD: FASKEN MARTINEAU DUMOULIN S.E.N.C.R.L. ...
FCA

Leonard v. Canada, 2022 FCA 195

In 2004 or 2005, Mr. Leonard became acquainted with Mr. Anderson, who was a real estate developer. ... HIS MAJESTY THE KING   AND DOCKET: A-152-21   STYLE OF CAUSE: CAROL TENNEY v. ... François Daigle Deputy Attorney General of Canada For HIS MAJESTY THE KING   ...
FCTD

Simmons v. Canada (Attorney General), 2021 FC 202

Since 2005, relief may be claimed only with respect to the ten years preceding the request. [19] The process for requesting relief and the factors that the CRA considers in determining such requests are set out in a CRA Information Circular. ... Piper see paragraph 22, above) as “directions from the court itself.” [37] In response to Mr. ... DATED: March 4, 2021   APPEARANCES: Jeff Pniowsky Matthew Dalloo   For The Applicant   Anita Balakumar Samantha Gergely   For The Respondent   SOLICITORS OF RECORD: Thompson Dorfman Sweatman LLP Barristers and Solicitors Winnipeg, Manitoba   For The Applicant   Attorney General of Canada Winnipeg, Manitoba   For The Respondent     ...

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