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TCC

Loblaw Financial Holdings Inc. v. The Queen, 2018 TCC 263

., Appellant, and HER MAJESTY THE QUEEN, Respondent.     By: The Honourable Justice Campbell J. ... So, let me look at what transpired with respect to settlement offers, as this remains the sole determinative factor for an award of costs. [17]   The Appellant made an offer to the Respondent on March 15, 2018, “predicated on the basis that the taxpayer complied with the technical requirements of the Act, the waivers preclude the Minister from reassessing the 2001 to 2005 taxation years on the basis of the GAAR, and the GAAR applied to Glenhuron Bank’s years 2006 to 2013.” [18]   The Respondent rejected that offer on March 20, 2018 and countered as follows: We are in receipt of the appellant’s settlement offer dated March 15, 2018. ... AND HER MAJESTY THE QUEEN         REASONS RESPECTING SUBMISSIONS ON COSTS BY: The Honourable Justice Campbell J. ...
TCC

Wilford v. M.N.R., 2011 TCC 6

Weisman" Weisman D.J.         Citation: 2011 TCC 6 Date: January 7, 2011 Dockets: 2009-3411(EI) 2009-3637(CPP) BETWEEN:   ALLEN WILFORD, Appellant, and   THE MINISTER OF NATIONAL REVENUE, Respondent, and   SUSAN BONNAR (GIORDANO), Intervener.       ... M.N.R. (“ Wiebe Door ”) [3]; and 671122 Ontario Limited v. Sagaz Industries Canada Inc. (“ Sagaz ”) [4]. ... No. 375 (F.C.A.) [10] Above, footnote 4, at paragraph 47 [11] Above, footnote 7 [12] Above, footnote 2, at paragraph 17 [13] Woodland Insurance Ltd. v.M.N.R., [2005] T.C.J. ...
TCC

Deragon v. The Queen, 2015 TCC 294

(hereinafter " Gestions "), of Transport N.J.N. Inc. (hereinafter " N.J.N. "), of Transport F. Audet Inc. (hereinafter " Audet ") and of Transport Serge Durivage Inc. ... (hereinafter " Frapar ") and of P&W Intermodal Inc. (hereinafter " P&W ").  ...
TCC

Villeneuve v. M.N.R., 2014 TCC 224

Masse” Masse D.J.     Translation certified true on this 27th day of August 2014 Margarita Gorbounova, Translator     Citation: 2014 TCC 224 Date: 20140715 Docket: 2012-4735(EI) BETWEEN: JACQUES VILLENEUVE, Appellant, and THE MINISTER OF NATIONAL REVENUE, Respondent. ... Canada (Minister of National Revenue), 2005 FCA 334, [2005] F.C.J. No. 1720 (QL), at paragraph 12. [30]         What is the interaction between Quebec civil law and the common law in the interpretation of a contract of employment or a contract of enterprise concluded in Quebec? ... Pentney Deputy Attorney General of Canada Ottawa, Canada     ...
TCC

Olson v. The Queen, 2007 TCC 87

On July 25, 2005, the Minister reassessed the Appellant for the 2000 and 2001 taxation years to reduce the taxable income that had previously been assessed by $3,434 and $52,929, respectively, calculated as set out in the attached Schedule "A". ... CITATION:                                        2007TCC87 COURT FILE NO.:                             2005-3454(IT)G STYLE OF CAUSE:                           Shane E. ... Beaubier DATE OF JUDGMENT:                     February 20, 2007 APPEARANCES: For the Appellant: The Appellant himself Counsel for the Respondent: Brooke Sittler COUNSEL OF RECORD:        For the Appellant:                           Name:                                                   Firm:        For the Respondent:                     John H. ...
TCC

Glynn v. The Queen, 2007 TCC 83 (Informal Procedure)

REASONS FOR JUDGMENT Angers J. [1]      The appellant is appealing a notice of reassessment dated September 29, 2005, in which the Minister of National Revenue (Minister) disallowed the claim of an allowable business investment loss (ABIL) for the appellant's 2004 taxation year and also denied the appellant's request to have the unused portion of the ABIL carried back to her 2003 taxation year. [2]      The appellant reported a total business investment loss (BIL) of $35,864 in relation to Thomas Oxford Inc. ... CITATION:                                        2007TCC83 COURT FILE NO.:                             2006-1748(IT)I STYLE OF CAUSE:                           Janet M. ... Her Majesty the Queen PLACE OF HEARING:                      St. John's, Newfoundland DATE OF HEARING:                        December 4, 2006 REASONS FOR JUDGMENT BY:     The Honourable Justice François Angers DATE OF JUDGMENT:                     March 13, 2007 APPEARANCES: For the Appellant: The Appellant herself Counsel for the Respondent: Martin Hickey COUNSEL OF RECORD:        For the Appellant:                           Name:                                                   Firm:        For the Respondent:                     John H. ...
TCC

McKenzie v. The Queen, 2017 TCC 56 (Informal Procedure)

In the 2005 taxation year, the taxpayer received a lump sum amount on the redemption of the US IRA. ...   [45]         As I stated earlier, subsection 70(5) of the Act is not applicable in this appeal. ... Pentney Deputy Attorney General of Canada Ottawa, Canada     [1]           Unless otherwise stated, all amounts set out in these Reasons for Judgment are in Canadian denominations. [2]           Dated February 19, 2017. [3]           RSC 1985, c 1 (5th Supp). ...
TCC

Dr. Brian Hurd Dentistry Professional Corporation v. The Queen, 2017 TCC 142 (Informal Procedure)

This result would be contrary to the intent of Schedule V which is meant to exempt the majority of health care services. [44]         I am of the view that if I had concluded that the Appellant provided multiple supplies, then applying a textual, contextual and purposive analysis as the decision in Canada Trustco Mortgage Co. v Canada, 2005 SCC 54, [2005] 2 SCR 601 would have me do, the supply of the orthodontic appliance would be zero-rated pursuant to section 11.1 of Schedule VI, Part II of the Act. ... Woon   COUNSEL OF RECORD: For the Appellant: Name:     Firm:   For the Respondent: Nathalie G. Drouin Deputy Attorney General of Canada Ottawa, Canada     ...
TCC

Pinnacle International Realty Group II Inc. v. The King, 2023 TCC 161

De Cotiis, Hancock Bruckner Eng + Wright Architects (the Architects ”) provided a design rationale and landscape concept for the Taylor Project. ... It retained Mondiale to provide general contractor services to the Taylor Project.- The Taylor Project was substantially completed by November 2005 at a total cost, including land, of $37,550,345. An occupancy permit was issued on December 16, 2005. The Taylor Project was composed of 251 condominium and townhouse units.- The Partnership earned a profit of approximately $11.5 million on the sale of the condominium units. [30] The total purchase price for the Lands was paid by a $1 million deposit, a $3,195,800 payment financed by the Bank of Montreal (“ BMO ”) and a $2,218,194.10 payment made by the Appellant. ...
TCC

Odette (Estate) v. The Queen, 2021 TCC 65

(the Act ”). As a result, paragraph 118.1(13)(c) of the Act was triggered. ... (Canada Trustco Mortgage Co. v Canada, [2005] 2 S.C.R. 601, 2005 SCC 54 (SCC) at para 11). ... Rossiter, Chief Justice DATE OF JUDGMENT: September 28, 2021 APPEARANCES: Counsel for the Appellant: Rebecca Potter Counsel for the Respondent: Dominik Longchamps Andrew Miller COUNSEL OF RECORD: For the Appellant: Name: Rebecca Potter   Firm: Thorsteinssons LLP For the Respondent: François Daigle Deputy Attorney General of Canada Ottawa, Canada     ...

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