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TCC

McPherson v. The Queen, 2006 TCC 648

Specifically the Appellant said: ·         He met with Henry Thill; ·         He talked to Pasquale Cusano ("Cusano"); ·         He met with and talked to his brother, Stuart McPherson; ·         He met with and talked to the lawyer, James Comparelli ("Comparelli"); ·         He talked with his accountant, James McPherson; ·         He talked with John McCoach, the compliance officer at his employer, Yorkton Securities Ltd.; ·         He read and relied upon a legal opinion from Mr. ... R., [2005] 3 C.T.C. 2068.) QQ.    The Appellant also acknowledged that his brother, Stuart McPherson, was one of Mr. ... R., [2005] 3 C.T.C. 2068: The Appellant claimed to have donated $30,000.00 in 1997 to a charitable organization (A.B.L.E.). ...
TCC

Chamard v. The Queen, 2012 TCC 2

The Queen, 2012 TCC 2           Docket: 2010-190(GST)G BETWEEN: MARTINE CHAMARD, Appellant, and   HER MAJESTY THE QUEEN, Respondent.   ... Signed at Ottawa, Canada, this 9th day of January 2012.   “Paul Bédard” Bédard J.               ... Signed at Ottawa, Canada, this 9th day of January 2012.       “Paul Bédard” Bédard J.               ...
TCC

Ouahidi c. La Reine, 2007 TCC 119 (Informal Procedure)

La Reine, 2007 TCC 119 (Informal Procedure)           Docket: 2006-2222(GST)I BETWEEN: ESTHER OUAHIDI, Appellant, and   HER MAJESTY THE QUEEN, Respondent. ... Indeed, upon reading the divorce settlement of November 14, 2006, between the Appellant and Ralph Abergel, which can be found at tab 6 of Exhibit A-1, it can be seen that   (a)      initially, the Appellant owned 50% of the issued and outstanding share capital of Estéral Inc., and the other 50% was held by Ralph Abergel;   (b)     initially, Appellant held 50% of the issued and outstanding share capital of Brouillard Lepage Inc., and the other 50% was held by Ralph Abergel;   (c)     on September 25, 2005, the Appellant and Ralph Abergel purchased, as equal co-owners, three vacant lots in the city of Longueuil known as lots 2588664, 2588665 and 2588666, in the Quebec cadastre, Chambly registration division (the Du Cerf properties);   (d)     the Appellant and Ralph Abergel also purchased a commercial building, located at 2220 Marie‑Victorin Boulevard in Longueuil, as equal co-owners;   (e)      on July 29, 1998, Ralph Abergel granted the Appellant a second hypothec on a commercial building located at 2174 Marie‑Victorin Boulevard in Longueuil ... Signed at Montréal, Quebec, this 22nd day of March 2007.       "Réal Favreau" Favreau J.     ...
TCC

Laurin v. The Queen, 2007 DTC 236, 2006 TCC 634

Bissonnette;            q)        the Appellant did not use his mailing address in the Turks & Caicos Islands;            r)        the Appellant maintained an American cellular telephone from about 1997 through the 2000 taxation year;            s)        the Appellant was divorced throughout the taxation years and has two ex-wives;            t)         the Appellant has three sons, Guy, Stephane and Sacha whose years of birth are 1959, 1970 and 1974, respectively;            u)        the Appellant's three sons all live in the province of Quebec;            v)        the Appellant has two brothers and three sisters;            w)       four of the Appellant's five siblings are known to live in the province of Quebec;            x)        the Appellant was involved in a common law relationship with Paule Darveau during the taxation years in issue;            y)        the Appellant and Paule Darveau built a home together in St. ... The Queen, [2005] 4 C.T.C. 2260, in which the day of arrival is not counted, the total days spent by the appellant in Canada are significantly less. ... M.N.R., 2005 TCC 112, I quoted 1084767 Ontario Inc. (c.o.b. Celluland) v. ...
TCC

Constantin v. The Queen, 2014 TCC 327 (Informal Procedure)

(i)      one of the arguments for reselling the immovables within a short time was that the rents were too low even though the appellant          (i)   has a lot of experience and could not have been unaware that the price of income properties is determined on the basis of rents;          (ii)  made a profit on each disposition of the income properties;          (iii) declared capital gains of $224,858 for the 2005 to 2009 taxation years; (j)            one of the appellant’s real estate agents was Paul-André Huard, an associate of the appellant’s spouse and of the Trust in a number of real estate transactions; (k)          Mr.  ... Signed at Ottawa, Canada, this 6th day of November 2014. Judge Favreau Favreau J. ... Pentney Deputy Attorney General of Canada Ottawa, Canada       ...
TCC

9041-6868 Québec Inc. c. M.R.N., 2004 TCC 648

Translation certified true on this 6 th day of January 2005. Wendy Blagdon, Translator Citation: 2004TCC648 Date: 20040927 Docket: 2003-1279(EI) BETWEEN: 9041-6868 QUÉBEC INC., Appellant, and THE MINISTER OF NATIONAL REVENUE, Respondent. ... The following is an excerpt from this decision:             [...]             ... Translation certified true on this 6 th day of January 2005. Wendy Blagdon, Translator CITATION: 2004TCC648 COURT DOCKET NO: 2003-1729(EI) STYLE OF CAUSE: 9041-6868 Québec Inc. and M.N.R. ...
TCC

Langelier v. The Queen, 2013 DTC 1256 [at at 1435], 2013 TCC 322 (Informal Procedure)

Signed at Ottawa, Canada, this 22nd day of October 2013.     "Réal Favreau" Favreau J.           ... Canada, 2005 SCC 54, I do not believe that Parliament's intent was to permit a taxpayer to deduct moving expenses in circumstances where a taxpayer performed new duties with the same employer at the same business location ...   [24]         For these reasons, the appeal is dismissed.     Signed at Ottawa, Canada, this 22nd day of October 2013.       ...
TCC

Barel v. The Queen, 2009 TCC 156

The Queen, 2009 TCC 156         Docket: 2007-3942(IT)G BETWEEN: PAUL C.J. ... BAREL, Appellant, and   HER MAJESTY THE QUEEN, Respondent.       REASONS FOR JUDGMENT   V.A. ... At the end of the year 2005, the Appellant transmitted the required form for the withdrawals of funds from the 401(k) Plan to the plan’s trustee, The Vanguard Group.   9.       ...
TCC

Swain v. The Queen, 2012 DTC 1086 [at at 2921], 2012 TCC 46

Signed at Ottawa, Canada, this 10th day of February 2012.         "Patrick Boyle" Boyle J.       ... EM Diagnostics and Discovery Biotech had been clients of the firm since 2000 and the firm continued to do legal work in 2004 and 2005. ...
TCC

Bemco Confectionery and Sales Ltd. v. The Queen, 2015 TCC 48

The Queen, 2015 TCC 48     Docket: 2013-4832(GST)G BETWEEN:   BEMCO CONFECTIONERY AND SALES LTD., Appellant, and HER MAJESTY THE QUEEN, Respondent.   ... Canada, 2005 FCA 104 at para 35. This, again, would be a matter that should be left to the determination of the trial judge who would have the benefit of hearing all of the evidence. [49]         In the case of pleadings that lack specificity, this Court has also held that the appropriate course of action would be a demand for particulars rather than a motion to strike: Kulla v. The Queen, 2005 TCC 136 at para 15; Kopstein v. Canada, 2010 TCC 448 at para 64 and 65. ...

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