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TCC
Montana Reclaimed Lumber Co. v. The Queen, 2018 TCC 51
Pecora started with the Appellant in 2005 and is the brother-in-law of the founder of the Appellant. [5] Mr. ... The Queen, 2005 FCA 104 at paragraph 35. The Appellant admitted in its Notice of Appeal that it might be possible with enough time and effort to determine the origin of the wood. ... APPENDIX B CITATION: 2018 TCC 51 COURT FILE NO.: 2014-3418(SLP)G STYLE OF CAUSE: MONTANA RECLAIMED LUMBER CO. v. ...
TCC
Wolsey v. The Queen, 2016 TCC 236
PSC had never filed tax returns. [4] Mr. Wolsey filed his appeal in 2005 but the relevant period of time for the purposes of this Application is June to October of 2014. ... Wolsey’s conduct between the time his appeal was filed in 2005 and the time it was dismissed at the October 9, 2014 status hearing. ... Pentney Deputy Attorney General of Canada Ottawa, Canada [1] 2008 TCC 680 [2] 2012 TCC 144 [3] 2006 TCC 575 [4] Mr. ...
TCC
Edison Transportation, LLC v. The Queen, 2016 TCC 80
In Hammill v The Queen, 2005 FCA 252, 2005 DTC 5397, Noel J.A., in refuting the submission by the appellant’s counsel therein that the Court was bound by the facts as admitted, stated at paragraph 31: 31 In an appeal against an assessment under the Act, the outcome does not belong to the parties. ... Pizzitelli DATE OF JUDGMENT: April 6, 2016 APPEARANCES: Counsel for the Appellant: Joel A. ... Pentney Deputy Attorney General of Canada Ottawa, Canada ...
TCC
6610048 Canada Inc. v. The Queen, 2019 TCC 255
Desbiens. [43] Mr. Duchaine has always worked in single-family and bi-generational home construction industry and the condominium unit construction industry in association with François Barnabé (Le Groupe Habitation domicil) and Laurent Labrecque (Les développements Domicil Inc., Les développements immobiliers Domicil Inc. and Corporation immobilière Ténor Inc.). [44] Along with his activities as a builder and real estate developer, in 2005 Mr. ... Lot subdivision permits for Boisé de La Pinière were obtained in December 2005, but development was delayed in 2008-2009. [47] During his testimony, Mr. ... Drouin Deputy Attorney General of Canada Ottawa, Canada ...
TCC
Ike Enterprises Inc. v. The Queen, 2017 TCC 59
Those food products are as follows: 1. Crystallized ginger; 2. ... Canada, 2005 SCC 54, [2005] S.C.J. 56: 11. (…) There is no doubt today that all statutes, including the Income Tax Act, must be interpreted in a textual, contextual and purposive way. ... Smith DATE OF JUDGMENT: April 12, 2017 APPEARANCES: Counsel for the Appellant: Michel Bourque Jacqueline A. ...
TCC
Barnwell v. The Queen, 2015 DTC 1115 [at 724], 2015 TCC 98 (Informal Procedure), aff'd 2016 FCA 150
The report listed two other individuals as directors and officers (president and treasurer) of the corporation commencing July 10, 2005. [22] In cross-examination, the Appellant stated that he viewed Mr. ... Austin testified that he left Canada in 2000 and returned in 2005. He stated that the idea for Whitesand was “hatched” at the Appellant’s home with another individual, who was the editor of the magazine at that time. ... Pentney Deputy Attorney General of Canada Ottawa, Canada [1] Lines 5 to 8 of page 7 of the Transcript ...
TCC
Raymond v. The Queen, 2016 TCC 35 (Informal Procedure)
Miller J. Docket: 2015-1106(IT)I BETWEEN: GILBERT LUDLOW, Appellant, and HER MAJESTY THE QUEEN, Respondent. ... No single factor predominates: DeCosta v The Queen, 2005 TCC 545. Analysis A. ... Appendix A 2006-01-01 to 2006-03-31 As Filed Per Audit Per Appeals Sales $20,834.00 $20,834.00 $17,227.36 GST collectible $ 1,196.20 $ 1,196.20 $ 1,205.92 ITCs $ 823.43 $ 508.50 $ 762.53 Net Tax $ 372.77 $ 687.70 $ 443.39 Gross Negligence Penalties (GNP) $ 78.73 $ 15.23 2006-04-01 to 2006-06-30 As Filed Per Audit Per Appeals Sales $40,775.00 $40,775.00 $35,724.37 GST collectible $ 2,500.01 $ 2,500.01 $ 2,500.71 ITCs $ 1,643.47 $ 1,033.19 $ 1,242.84 Net Tax $ 856.54 $ 1,466.82 $ 1,254.01 Gross Negligence Penalties $ 152.57 $ 100.16 2006-07-01 to 2006-09-30 As Filed Per Audit Per Appeals Sales $54,906.00 $54,906.00 $49,316.19 GST collectible $ 2,915.47 $ 2,915.47 $ 2,958.97 ITCs $ 1,978.46 $ 1,198.31 $ 1,377.89 Net Tax $ 937.01 $ 1,717.16 $ 1,581.08 Gross Negligence Penalties $ 195.04 $ 150.14 2006-10-01 to 2006-12-31 As Filed Per Audit Per Appeals Sales $21,416.00 $21,416.00 $20,711.42 GST collectible $ 1,212.26 $ 1,212.26 $ 1,242.69 ITCs $ 1,514.89 $ 1,210.26 $ 1,444.09 Net Tax ($ 302.63) $ 2.00 ($ 201.40) Gross Negligence Penalties $ 76.16 $ 17.70 2007-01-01 to 2007-03-31 As Filed Per Audit Per Appeals Sales $63,745.00 $63,745.00 $58,391.08 GST collectible $ 3,463.85 $ 4,170.04 $3,503.46 ITCs $ 2,906.37 $ 2,106.48 $2,536.39 Net Tax $ 557.48 $ 2,063.56 $967.08 Gross Negligence Penalties $ 199.97 $92.50 2007-04-01 to 2007-06-30 As Filed Per Audit Per Appeals Sales $52,302.00 $52,302.00 $47,451.75 GST collectible $ 2,912.41 $ 3,751.08 $ 2,847.11 ITCs $ 2,768.37 $ 1,845.98 $ 2,328.82 Net Tax $ 144.04 $ 1,905.10 $ 518.29 Gross Negligence Penalties $ 230.60 $ 109.89 2007-07-01 to 2007-09-30 As Filed Per Audit Per Appeals Sales $42,730.00 $42,730.00 $41,432.54 GST collectible $ 2,534.07 $ 2,795.81 $ 2,485.95 ITCs $ 1,686.31 $ 1,118.33 $ 1,141.29 Net Tax $ 847.76 $ 1,677.48 $ 1,344.66 Gross Negligence Penalties $ 141.99 $ 136.26 2007-10-01 to 2007-12-31 As Filed Per Audit Per Appeals Sales $27,021.00 $27,021.00 $26,003.00 GST collectible $ 1,529.53 $ 1,747.56 $ 1,560.18 ITCs $ 1,503.26 $ 968.44 $ 1,004.20 Net Tax $ 26.27 $ 779.12 $ 555.98 Gross Negligence Penalties $ 133.70 $ 124.77 2008-01-01 to 2008-03-31 As Filed Per Audit Per Appeals Sales $23,560.00 $23,560.00 $23,560.00 GST collectible $ 1,446.33 $ 1,446.33 $ 1,178.00 ITCs $ 1,400.55 $ 263.46 $ 592.77 Net Tax $ 45.78 $ 1,182.87 $ 585.23 Gross Negligence Penalties $ 284.27 $ 201.95 2008-04-01 to 2008-06-30 As Filed Per Audit Per Appeals Sales $35,002.00 $35,002.00 $35,002.00 GST collectible $ 1,666.76 $ 1,666.76 $ 1,750.10 ITCs $ 1,642.52 $ 425.25 $ 898.08 Net Tax $ 24.24 $ 1,241.51 $ 852.03 Gross Negligence Penalties $ 304.32 $ 186.11 2008-07-01 to 2008-09-30 As Filed Per Audit Per Appeals Sales $45,626.00 $45,626.00 $45,626.00 GST collectible $ 2,043.37 $ 2,043.37 $ 2,281.30 ITCs $ 1,950.44 $ 559.69 $ 1,118.62 Net Tax $ 92.93 $ 1,483.68 $ 1,162.68 Gross Negligence Penalties $ 347.69 $ 207.96 2008-10-01 to 2008-12-31 As Filed Per Audit Per Appeals Sales $29,385.00 $29,385.00 $29,385.00 GST collectible $ 1,399.28 $ 1,399.28 $ 1,469.25 ITCs $ 1,116.26 $ 360.52 $ 1,713.60 Net Tax $ 283.02 $ 1,038.76 ($ 244.35) Gross Negligence Penalties $ 188.94 NIL CITATION: 2016TCC35 COURT FILE NO.: 2015-146(IT)I; 2015-1106(IT)I; 2015-158(GST)I STYLE OF CAUSE: SHELLEY RAYMOND AND HER MAJESTY THE QUEEN GILBERT LUDLOW AND HER MAJESTY THE QUEEN SHELLEY RAYMOND & GILBERT LUDLOW AND HER MAJESTY THE QUEEN PLACE OF HEARING: Toronto, Ontario DATE OF HEARING: October 28, 2015 REASONS FOR JUDGMENT BY: The Honourable Justice Valerie Miller DATE OF JUDGMENT: February 10, 2016 APPEARANCES: Agent for the Appellant: Susan Cunningham Counsel for the Respondent: Tony Cheung COUNSEL OF RECORD: For the Appellant: Name: Firm: For the Respondent: William F. ...
TCC
Corvalan v. The Queen, 2006 DTC 2907, 2006 TCC 200
.____________________________________________________________________ Appeal heard on February 17 and November 16, 2005 at Vancouver, British Columbia Before: The Honourable Justice Diane Campbell Appearances: Counsel for the Appellant: Samantha Mason Counsel for the Respondent: Bruce Senkpiel____________________________________________________________________ JUDGMENT The appeal from the assessment made under the Income Tax Act for the 1997 taxation year is dismissed, with costs, in accordance with the attached Reasons for Judgment. ... The Evidence: Ruben Corvalan [4] The Appellant was born in Chile and moved to Canada in 1974. ... Note 11: See P.W. Hogg, J.E. Magee, "Principles of Canadian Income Tax Law", 2d ed. 1997, para. 16.3(b). 21 The Tax Court judge was mindful of the difficulty of the task he was about to embark on. ...
TCC
Mahdi v. The Queen, 2018 TCC 149
Instead, on June 18, 2010, the CRA resubmitted certain questions to Khaled for response, this time pertaining to business details and carried back business losses for 2005 through 2009 taxation years. ... The Queen, 2005 TCC 545, at paragraph 11 as: a) the magnitude of the omission in relation to the income declared, b) the opportunity the taxpayer had to detect the error, c) the taxpayer’s education and apparent intelligence, d) genuine effort to comply. 3. ... Drouin Deputy Attorney General of Canada Ottawa, Canada ...
TCC
Semenov v. The Queen, 2018 TCC 58
Li testified that, after her father came to Canada in 2005, he did not return to Kazakhstan. [45] When cross-examined, Ms. ... The Supreme Court of Canada has indicated that a court may properly take judicial notice of facts that are capable of immediate and accurate demonstration by resort to readily accessible sources of indisputable accuracy; see R. v Krymowski, (2005) 249 DLR (4 th) 28 (SCC); The Queen v Find, 2001 SCC 32; and The Queen v Spence, 2005 SCC 71. ... Li testified that he came to Canada on November 30, 2005 (ibid., p. 18, line 17). ...