Search - 2005年 抽纸品牌 质量排名
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FCA
Fortin v. Canada, 2008 FCA 248
Instead, she received the reasons for judgment signed almost seven months later, which are intended to be the reasons for judgment delivered orally at the hearing of November 23, 2005, but which have been [translation] “amended for greater clarity and precision” ... Nadon” J.A. “J.D. Denis Pelletier” J.A. “Johanne Trudel” J.A. ... TRUDEL, J.A. DATED: August 6, 2008 APPEARANCES: Michel Lamarre FOR THE RESPONDENT SOLICITORS OF RECORD: John H. ...
FCA
Dionne v. Canada, 2006 FCA 79
Date: 20060220 Docket: A-146-05 Citation: 2006 FCA 79 CORAM: ROTHSTEIN J.A. ... Dionne's appeal only with respect to part of his legal expenses (2005 TCC 354). [2] We see no error in the Tax Court decision in relation to legal expenses and incidental expenses. [3] However, with respect to paragraphs 8(1)(h) and (h.1), counsel for the Crown, to her credit, referred us to another Tax Court decision, Champaigne v. ... FEDERAL COURT OF APPEAL NAMES OF COUNSEL AND SOLICITORS OF RECORD DOCKET: A-146-05 STYLE OF CAUSE: CLAUDE DIONNE Appellant and HER MAJESTY THE QUEEN Respondent PLACE OF HEARING: TORONTO, ONTARIO DATE OF HEARING: FEBRUARY 20, 2006 REASONS FOR JUDGMENT OF THE COURT BY: (ROTHSTEIN, SHARLOW, MALONE JJ.A.) ...
FCA
Brassard v. Canada, 2017 FCA 205
The appraiser’s opinion was that the property was worth $175,000 in October 2005, the date at which the transfer between the brothers took place. ... In the end, the Minister proceeded on the basis that the value of the property as of the date of the transfer, October 2005, was $120,600. [3] In calculating the benefit received by Mr. ... Drouin Deputy Attorney General of Canada For The Respondent ...
FCA
Canada v. Landrus, 2009 DTC 5085 [at at 5840], 2009 FCA 113
- Pursuant to a Purchase Agreement dated December 28, 1994, Roseland II sold all of its condominium units to RPM for $4,448,000. ... Canada, 2005 SCC 54, [2005] 2 S.C.R. 601 (Canada Trustco Mortgage) (paras. 44 and 45), the Tax Court Judge first conducted a contextual and purposive analysis of the provisions relied upon by the respondent in order to claim the terminal loss, specifically subsection 20(16) (Reasons, paras. 98 and 99) ... Canada, 2005 DTC 5538, the Supreme Court said at paragraph 51 that: “The partnership rules under s. 96 are predicated on the requirement that partners in a partnership pursue a common interest in the business activities of the partnership, in a non-arm's length relationship. …” [102] It is not disputed that, at the time of the transfer of the partnership property by Roseland II to RPM, the partners of Roseland II were carrying on business in common in a non-arm’s length relationship. ...
FCA
Tesainer v. Canada, 2009 DTC 5749, 2009 FCA 33
SHARLOW J.A. PELLETIER J.A. BETWEEN: A-69-08 SYLVANO TESAINER Appellant and HER MAJESTY THE QUEEN Respondent A-70-08 MARY LYNNE TESAINER Appellant and HER MAJESTY THE QUEEN Respondent Heard at Toronto, Ontario, on January 14, 2009. ... Canada, [2005] 1 S.C.R. 113. Justice McArthur accepted that argument because, as he explained at paragraph 17 of his reasons: […] (i) it replaced the Appellants’ capital investment […]; (ii) the Appellants’ lawsuit was for the amount of their investment; (iii) they claimed the return of their $100,000 and received $98,300; (iv) the documentary evidence clearly points to it being a return of capital; and (v) the partnership agreement was in reality at an end in 1991 ... Sharlow” J.A. “I agree. M. Nadon J.A.” “I agree. J.D. ...
FCA
Folz Vending Company Limited v. Canada, 2008 FCA 160
LÉTOURNEAU J.A. BLAIS J.A. BETWEEN: FOLZ VENDING COMPANY LIMITED Appellant and HER MAJESTY THE QUEEN Respondent Hearing held at Québec, Quebec, on April 28, 2008. ... Ontario (Minister of Finance), [2005] O.J. No. 3179, where the judge wrote at paragraph 20: In any event, just because compliance with the Act may be difficult or may result in the imposition of a cap on the effective purchase price of products sold through the vending machines does not affect the legal duty of vendors to comply with the Act. ... BLAIS J.A. DATED: May 1, 2008 APPEARANCES: Gaétan Drolet FOR THE APPELLANT Gatien Fournier Andrew Miller FOR THE RESPONDENT SOLICITORS OF RECORD: Gaétan Drolet Sainte-Foy, Quebec FOR THE APPELLANT John H. ...
FCA
Kossow v. Canada, 2014 DTC 5017 [at at 6622], 2013 FCA 283
Kossow’s appeal. I. Facts [3] In 2000, 2001, and 2002, Ms. ... On September 9, 2005, the Minister issued a subsequent reassessment, disallowing the entire tax credit received for the 2002 tax year ... [22] As stated in Canada Trustco Mortgage Co. v. Canada, 2005 SCC 54, “[t]he textual, contextual and purposive interpretation of specific provisions of the Income Tax Act is essentially a question of law but the application of these provisions to the facts of a case is necessarily fact-intensive” (paragraph 44). ...
FCA
Hauser v. Canada, 2006 FCA 216
EVANS J.A. PELLETIER J.A. BETWEEN: RAY HAUSER Appellant and HER MAJESTY THE QUEEN Respondent Heard at Ottawa, Ontario, on June 7, 2006. ... EVANS J.A. PELLETIER J.A. BETWEEN: RAY HAUSER Appellant and HER MAJESTY THE QUEEN Respondent REASONS FOR JUDGMENT NOËL J.A. [1] This is an appeal from a judgment of Rip J. of the Tax Court of Canada (2005 TCC 492) dismissing the appeals brought by Mr. ... [22] I would dismiss the appeal with costs. "Marc Noël" J.A. ...
FCA
Vine Estate v. Canada, 2015 DTC 5063 [at at 5880], 2015 FCA 125
On May 20, 2005 the CCRA auditor wrote to the Estate requesting certain information. ... Canada Trustco Mortgage Company, 2005 SCC 54, [2005] 2 S.C.R. 601, at paragraph 10). [45] In Aridi the main argument of the Crown related to the interpretation to be given to the words “the person filing the return”. ... Canada, 2005 SCC 25; [2005] 1 S.C.R. 301, Fish J. writing on behalf of the majority of the Supreme Court of Canada noted that: 74 I would explain the matter this way. ...
FCA
Canadian Forest Navigation Co. Ltd. v. Canada, 2017 FCA 39
The appellant was the sole shareholder in both companies. [5] In 2005 and 2006, the Foreign Affiliates, through resolutions by their respective boards of directors, issued a series of dividends to the appellant totalling approximately $250 million (CDN). ... Although the Minister was not given notice of these proceedings, the appellant informed the Minister of the outcome subsequent to each proceeding. [8] By notice of reassessment dated December 29, 2010, the Minister reassessed the appellant for the 2005 and 2006 taxation years. ... HER MAJESTY THE QUEEN PLACE OF HEARING: tORONTO, Ontario DATE OF HEARING: February 20, 2017 REASONS FOR JUDGMENT BY: BOIVIN J.A. ...