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TCC

Aboud Schofield v. The King, 2022 TCC 142 (Informal Procedure)

x Yes ¨ No Answer yes even if you provide an allowance or a reimbursement in respect of some or all such expenses. ... ¨ Yes x No If yes, indicate the amount and type of expenses that were: (...) 7. ... The Queen, 2005 TCC 564 [Karda TCC], affirmed by 2006 FCA 238 [Karda FCA]. [10] Karda TCC, ibid. at paragraph 34. [11] Karda TCC, ibid. at paragraph 33. [12] Transcript at pages 73 and 74. [13] Exhibits A‑2 and A‑3. [14] Blott v The Queen, 2018 TCC 1. [15] Tulman v. ...
TCC

9291-8002 Québec Inc. v. The King, 2022 TCC 123

The Queen, 2005 TCC 65 [Sandia], this Court stated that in tax cases involving penalties, and more specifically misrepresentation, "questions into the circumstances of the misrepresentation are proper" on examination for discovery. ... Conclusion [34] For these reasons, the motion is dismissed with one set of costs to the respondent.   ... Côte-St-Luc, QC For the Respondent: François Daigle Deputy Attorney General of Canada Ottawa, Canada   ...
TCC

Lichtman v. The Queen, 2017 TCC 252 (Informal Procedure)

TABLE OF CONTENTS I.          Introduction: 1 II.        Appellant’s Position: 3 III.            ... Admissibility of Rabbi Eleff’s Expert Report: 26 a)         Properly Qualified Expert 26 b)        Relevance. 30 c)         Necessity in Assisting the Trier of Fact 32 d)        Exclusionary Rules. 33 VI.            ... (Canada Trustco Mortgage Co. v Canada, 2005 SCC 54, [2005] 2 SCR 601 at paragraph 10). [180]      According to the number of possible definitions contained in the Oxford English Dictionary, the scope of the word “congregation” is quite extensible. ...
TCC

Malone v. The King, 2025 TCC 43 (Informal Procedure)

Docket: 2022-1008(IT)I BETWEEN: BRANDON MALONE, Appellant, and HIS MAJESTY THE KING Respondent.   ... Docket: 2022-2602 (IT)I BETWEEN: BARBARA MALONE, Appellant, and HIS MAJESTY THE KING Respondent.   ... The Minister says the claimed amounts do not comply with the necessary Income Tax Act (the Act ”) provisions and other legal principles concerning charitable gifts and therefore are not eligible as charitable deductions. ...
TCC

University of Calgary v. The Queen, 2016 DTC 1006 [at 2522], 2015 TCC 321

Kinzner. [11]       PASF I, paragraph 8. [12]       PASF I, paragraph 10. [13]       PASF I, paragraph 11. [14]       PASF I, paragraph 19. [15]       PASF I, paragraphs 13, 14. [16]       PASF I, paragraph 15. [17]       See PASF I, Exhibit F. [18]       PASF I, paragraphs 8 and 9. [19]       Including the parking lots. [20]       PASF I, paragraph 8. [21]       Transcript, pages 30-54, testimony of Mr. ... Kinzner. [65]       Exhibit R3, page 373, shows the tax that was incurred between August 2005 and June 2007. [66]       The Appellant is entitled, under section 225, to claim an input tax credit for the reporting period in which the tax became payable or in a subsequent reporting period, subject to a two-year or four-year limitation period. ... Kinzner. [73]       PASF I, Exhibits B, C and D. [74]       PASF I, Exhibits B, C and D. [75]       Transcript, pages 19-32, testimony of Mr. ...
TCC

Howe v. The Queen, 2004 TCC 719

Vidatron agreed to match NM I's initial expenditures during the period from January 1, 1996 until the end of the term of the First JV Agreement on December 31, 2005. 9.          ... A.         Yes. Q.         And who did the general partner select? A.         ... A.        Yes there were. Q.         Do you know how many? A.         ...
TCC

Bousfield v. The King, 2022 TCC 169

Canton added $2,464 in revenue from December 2005 to Mr. Bousfield’s 2006 revenue. ... I have corrected the error here. [21] Reply, para. 6(i.19). [22] Exhibit A-2, Tab 21, pg. 30. [23] Notice of Appeal in appeal 2015-1002(IT)G, para. 10(d). [24] A-2, Tab 28, pg. 326. [25] Exhibit A-2, Tab 28, pg. 294; Exhibit R-2, unnumbered pg. 3. [26] Exhibit A-2, Tab 16 and Exhibits R-22, R-23, R-24 and R-25. [27] Exhibits R-24 and R-25. [28] Exhibit R-28. [29] $34,138 in non-cash fares / 55% = $62,069 in total fares. $62,069 in total fares x 45% = $27,931 in cash fares. [30] Exhibit R-27. [31] Exhibit R-30. [32] Exhibit R-27. [33] Exhibit R-28. [34] Exhibit R-30. [35] $44,504 total non-cash fares- $34,138 Hooper non-cash fares- $3,875 non-cash fares reported on white envelopes = $6,491 in non-cash fares from the missing white envelopes. [36] $6,491 non-cash fares / 20% non-cash ratio = $32,455 in total fares from missing white envelopes. $32,455 in total fares x 80% cash ratio = $25,964 in cash fares from missing white envelopes. [37] Exhibit R-27. [38] $2,464 in revenue from 2005 + $291 in credits = $2,756. [39] Exhibit R-19. [40] Exhibit A-2, Tab 18. [41] $25,337 × 6% GST / 4 quarters = $380.05. [42] $25,605 × 5% GST / 4 quarters = $320.06. [43] $45,509 in reduced taxi revenue + $2,756 in reduced Where 2 revenue + $947 in additional expenses = $49,211. [44] $49,584 in reduced taxi revenue + $3,072 in reduced Where 2 revenue + $2,012 in additional expenses = $54,668. [45] $46,265 in reduced taxi revenue + $4,440 in reduced Where 2 revenue + $780 in additional expenses = $51,485. [46] Exhibit R-30. [47] Mr. ... Hooper’s non-cash fares represented 76.8% of all non-cash fares in 2006 ($34,138 / $44,405). ...
TCC

R. v. Golini, 2016 TCC 174

Golini and Holdco under section 85 of the Income Tax Act (the Act ”).               ... In this regard, an RCA was recommended and implemented in 2005, through the auspices of a Royal Bank Insurance product. ... Miller J.                                               APPENDIX B                         CITATION: 2016 TCC 174 COURT FILE NO.: 2013-705(IT)G STYLE OF CAUSE: PAUL A. ...
TCC

Alexander v. The King, 2022 TCC 147

The King, 2022 TCC 147 Docket: 2015-3120(IT)G BETWEEN: SHIRLEY ALEXANDER, Appellant, and HIS MAJESTY THE KING, Respondent.   ... “Dominique Lafleur” Lafleur J.     Citation: 2022 TCC 147 Date: 20221122 Docket: 2015-3120(IT)G BETWEEN: SHIRLEY ALEXANDER, Appellant, and HIS MAJESTY THE KING, Respondent. ... In September 2005, the Minister further reassessed the Appellant and her spouse to deny 100% of the charitable donation tax credit claimed by the Appellant and her spouse for the 2001 and 2002 taxation years in respect of the 2001 Donation. ...
TCC

O'Hagan v. The King, 2023 TCC 52 (Informal Procedure)

The King, 2023 TCC 52 (Informal Procedure) Docket: 2013-3259(IT)I BETWEEN: SEAN O'HAGAN, Appellant, and HIS MAJESTY THE KING, Respondent.   ... Russell” Russell J.   Citation: 2023 TCC 52 Date: May 2, 2023 Docket: 2013-3259(IT)I BETWEEN: SEAN O'HAGAN, Appellant, and HIS MAJESTY THE KING, Respondent.   ... In this matter a deduction of $308,073 was claimed, with a loss carryback request that would have allowed for refund of the taxpayer’s entire tax for the years 2005 to 2008. ...

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