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TCC

Evoy Estate v. The Queen, 2016 TCC 263

Paris Appearances:   Counsel for the Appellant: Wilfrid Lefebvre Q.C. Taj Kudhail Counsel for the Respondent: Benoit Mandeville   AMENDED JUDGMENT           The appeal from the reassessments made under the Income Tax Act for the 2008, 2009 and 2010 taxation years is allowed, with costs to the Appellant, in accordance with the attached Reasons for Judgment.             ... Canada, 2005 SCC 54 at paragraph 10: It has been long established as a matter of statutory interpretation that “the words of an Act are to be read in their entire context ad in their grammatical and ordinary sense harmoniously with the scheme of the Act, the object of the Act, and the intention of Parliament”: see 65302 British Columbia Ltd. v. ...
TCC

Fengos v. The Queen, 2014 TCC 253 (Informal Procedure)

Later, he acquired other pharmacies, and at one point he owned 19 pharmacies. [7]              The period between 2005 and 2007 was very difficult for the appellant. ...   [15]         Mr. Lévis came to see the appellant every two or three months, but Mr.  ...   [30]         But what does it mean that “circumstances must be taken into account”? ...
TCC

Sheck v. The Queen, 2018 TCC 125 (Informal Procedure)

This was the amount of debt as of the end of the period October 31, 2005 to July 31, 2008, i.e. just prior to the aforementioned transfer date of August 18, 2008. [5]   On February 6, 2015 a certificate for the amount of $113,318 plus penalty and interest was registered in the Federal Court. ... Russell DATE OF JUDGMENT: June 29, 2018   APPEARANCES:   Agent for the Appellant: Ray Barnes Counsel for the Respondent: Jamie Hansen Patrick Cashman   COUNSEL OF RECORD: For the Appellant: Name:     Firm:   For the Respondent: Nathalie G. Drouin Deputy Attorney General of Canada Ottawa, Canada     ...
TCC

Blain v. M.N.R., 2015 TCC 162

Minister of National Revenue, 2005 FCA 334, para. 11): i. performance of work; ii. remuneration; and iii. a relationship of subordination. [27]         As the Federal Court of Appeal teaches us in 9041-6868 Québec inc. v. ... M.N.R., 2005 FCA 334, 350 N.R. 201.... [43]      In short, in my opinion there is no antinomy between the principles of Quebec civil law and the so‑ called common law criteria used to characterize the legal nature of a work relationship between two parties. ... Pentney Deputy Attorney General of Canada Ottawa, Canada     ...
TCC

Andrews v. The Queen, 2017 TCC 23 (Informal Procedure)

His request was granted. [3]              The net tax in issue is as follows: Periods: January 1 to December 31 Sales GST/HST Collectible Input Tax Credits Net Tax 2006 $47,548 $3,091 $339 $2,752 2007 $52,244 $3,983 $1,965 $2,018 2008 $69,510 $3,862 $1,535 $2,327 2009 $65,275 $3,476 $1,478 $1,998 2010 $68,845 $3,736 $1,302 $2,434 Total       $11,529   Facts [4]              During the period, the Appellant operated Canadian Auto Transport (“Canadian Auto”) as a sole proprietorship. ... ANDREWS AND HER MAJESTY THE QUEEN PLACE OF HEARING: London, Ontario DATE OF HEARING: October 27, 2016 REASONS FOR JUDGMENT BY: The Honourable Justice Valerie Miller DATE OF JUDGMENT: February 13, 2017   APPEARANCES:   For the Appellant: The Appellant himself Counsel for the Respondent: Jack Warren   COUNSEL OF RECORD: For the Appellant: Name:     Firm:   For the Respondent: William F. Pentney Deputy Attorney General of Canada Ottawa, Canada     ...
TCC

Coburn Realty Ltd. v. The Queen, 2006 TCC 245 (Informal Procedure)

Kamin Counsel for the Respondent: Amy Kendell____________________________________________________________________ JUDGMENT           The appeal from the assessment made under the Excise Tax Act, notice of which is dated July 26, 2005 and bears number 04BP-041270833232, is dismissed. ... GST of $21,883.12 was paid when the boat was imported. [2]      There are two issues:           a)        who owned the boat when the GST was paid?           ... July 11 & 12, 2003 Installation of Navigation Software. July 22, 2003                             A 6 day cruise. ...
TCC

Zhu v. The Queen, 2015 TCC 16

(“CSI”) from 2005 to June 6, 2008. 2.         Effective June 6, 2008, the appellant resigned from CSI. 3.         ... Woods” Woods J.   CITATION: 2015 TCC 16 COURT FILE NO.: 2012-2967(IT)G STYLE OF CAUSE: BING ZHU and HER MAJESTY THE QUEEN PLACE OF HEARING: Toronto, Ontario DATE OF HEARING: October 3, 2014 REASONS FOR JUDGMENT BY: The Honourable Justice Judith Woods DATE OF JUDGMENT: January 20, 2015   APPEARANCES:   For the Appellant: The Appellant himself Counsel for the Respondent: Diana Aird   COUNSEL OF RECORD: For the Appellant: Name: n/a   Firm:   For the Respondent: William F. Pentney Deputy Attorney General of Canada Ottawa, Ontario     ...
TCC

Whissell v. The Queen, 2016 TCC 133

These documents are found at Tabs 11 through 21 of the Joint Book (the Documents ”). ... Owen” Owen J.   APPENDIX A     CITATION: 2016 TCC 133 COURT FILE NO.: 2013-2846(IT)G STYLE OF CAUSE: GEORGE WHISSELL v. ... Forer   Firm: Tax Law LLP Edmonton, Alberta   For the Respondent: William F. ...
TCC

Commet v. The Queen, 2016 TCC 48 (Informal Procedure)

It required the Appellant to pay the net of the two amounts to his former spouse. [14]         Both parents’ income was considered in calculating the support amount because both parents have an obligation to support their children in accordance with their ability to contribute: Contino v Leonelli-Contino, 2005 SCC 63 at paragraph 32. ... Miller J.   CITATION: 2016TCC48 COURT FILE NO.: 2015-3552(IT)I STYLE OF CAUSE: DALE COMMET AND HER MAJESTY THE QUEEN PLACE OF HEARING: Edmonton, Alberta DATE OF HEARING: February 15, 2016 REASONS FOR JUDGMENT BY: The Honourable Justice Valerie Miller DATE OF JUDGMENT: February 23, 2016   APPEARANCES:   For the Appellant: The Appellant himself Counsel for the Respondent: Peter Basta   COUNSEL OF RECORD: For the Appellant: Name:     Firm:   For the Respondent: William F. Pentney Deputy Attorney General of Canada Ottawa, Canada     ...
TCC

Stackhouse v. The Queen, 2007 DTC 620, 2007 TCC 146

Signed at Ottawa, Canada, this 3rd day of April 2007. « François Angers » Angers J. ... Initially, that meant a provincial tax exemption on purchases of equipment and machinery for the farm, and only farmers could benefit from it. [15]     The appellant's investment in capital assets for the period from 1995 to 2005 totals $28,949 for her medical practice and $741,776 for the farming operation. ... Canada, [2005] 2 S.C.R. 601. [28]     In paragraph 82 of the Gunn decision (supra),the Federal Court of Appeal states that the "combination question" in section 31 of the Act is capable of bearing a more straightforward meaning than that assigned to it by Mr. ...

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