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TCC

Malenfant v. MNR, 92 DTC 2081, [1992] 2 CTC 2431 (TCC)

Words & Phrases (Vol. 4); Lord Nelson Hotel Co. Ltd. v. Halifax, [1956] 1 D.L.R. (2d) 5. ... André Tune, Le contrat de garde, Paris: Jouve & Cie, 1941, pages 94-123; 22. ... However, the amounts at issue are different: in 1979: $17,266 + $6,750 = $24,016 in 1980: $31,669 + $154,415 $186,084 in 1981: $38,450 The reasons and findings set forth in the case (88-2221) apply mutatis mutandis to the present appeal. ...
TCC

Anderson v. M.N.R., 2021 TCC 28

Anderson, was the following: I did that because I foreseen [sic] a problem…. ... Wheaton   Firm: Dobko & Wheaton For the Respondent: Nathalie G. Drouin Deputy Attorney General of Canada Ottawa, Canada     [1] Employment Insurance Act, SC 1996, c. 23, as amended. [2] Canada Pension Plan, RSC 1985, c. ... MNR, 2005 TCC 178, ¶19. [43] The email exchanges set out in Exhibit A-1, Tab 13 indicate that the office supplies provided by NIIA to Mr. ...
TCC

Radage v. The Queen, 96 DTC 1615, [1996] 3 CTC 2510 (TCC) (Informal Procedure)

Studies of higher orders of mammal chimpanzees, porpoises and certain other mammals indicate that the faculty of logical thought may be latent and capable of development. ... Errors of perception illusions and hallucinations are clearly embarrassing for such a theory; and indeed the argument from illusion (see ILLUSION) claims to disprove it. ... R. [1996] 2 C.T.C. 2005 (T.C.C.), Hillier v. R. [1996] 2 C.T.C. 2004 (T.C.C.), and Lamothe v. ...
TCC

Lin v. The Queen, 2020 TCC 26

Docket: 2014-4442(IT)G BETWEEN: WEI CHEN, Appellant, and HER MAJESTY THE QUEEN, Respondent.   ... HMQ, 2005 TCC 709. [108] In conducting such an arbitrary assessment, especially of an operating business, the Minister must use the proper method, apply it sensically and not exclude adjustments to enhance the assessment: Dziwenk v. ... Drouin Deputy Attorney General of Canada Ottawa, Canada   ...
TCC

LBL Holdings Limited v. The King, 2023 TCC 130

The King, 2023 TCC 130 Docket: 2012-4371(GST)G   BETWEEN: LBL HOLDINGS LIMITED, Appellant, and HIS MAJESTY THE KING, Respondent.   ... Cheung   JUDGMENT The appeals from the Reassessments dated June 23, 2005, made under the Excise Tax Act (Canada) for the Appellant’s January 1, 1999 to February 29, 2000 GST monthly reporting periods are allowed in accordance with the attached Reasons for Judgment, and the Reassessments are vacated. ... During 1999 to 2000, the Grandview accounts were generally COD cash before drop. ...
TCC

Abbass v. The King, 2023 TCC 169

The King, 2023 TCC 169 Docket: 2020-854(IT)G BETWEEN: MOSTAFA ABBASS, Appellant, and HIS MAJESTY THE KING, Respondent.   ... Gagnon” Gagnon J.   Citation: 2023 TCC 169 Date: 20231229 Docket: 2020-854(IT)G BETWEEN: MOSTAFA ABBASS, Appellant, and HIS MAJESTY THE KING, Respondent.   ... Luu: So, here, you mentioned an inflow of money in 2010 and an outflow of money in 2013, correct? ...
TCC

Claude Lamothe v. Her Majesty the Queen, [1996] 3 CTC 2423 (Informal Procedure)

.: In these appeals, which concern assessments for the 1991, 1992 and 1993 taxation years, the issue is the Minister of National Revenue’s refusal to allow the appellant a tax credit for a severe and prolonged mental or physical impairment pursuant to sections 118.3 and 118.4 of the Income Tax Act. ... R., [1996] 2 C.T.C. 2005 (T.C.C.), at page 6 [of original], I said: I should also say something about approach that this Court should take in these disability cases. ...
TCC

Total Energy Services Inc., 2024 TCC 12

Pizzitelli” Pizzitelli J.   Citation: 2024 TCC 12 Date: 20240202 Docket: 2016-367(IT)G BETWEEN: TOTAL ENERGY SERVICES INC., Appellant, and HIS MAJESTY THE KING, Respondent.   ... V Canada 2005 SCC 54 (“Canada Trustco”) at par 22 and Copthorne Holdings Ltd. ... AND HIS MAJESTY THE KING PLACE OF HEARING: Calgary Alberta Edmonton, Alberta DATE OF HEARING: June 20-24, 2022 & June 27-29, 2022 January 15, 2024 & January 16, 2024 REASONS FOR JUDGMENT BY: The Honourable Justice F.J. ...
TCC

Les Soudures Chagnon Ltée v. Minister of National Revenue, [1990] 1 CTC 2365, 90 DTC 1203

He referred the Court to definitions of the word "contingent" in French and English dictionaries; in French, the Dictionnaire Robert defines the word "contingent" as meaning, inter alia, ”... eventual, fortuitous, accidental, uncertain... conditional", the Dictionnaire Bélisle gives the following definition "What may or may not happen, v. accidental, casual, conditional, eventual, fortuitous, uncertain, chance...”. ... & R. Enterprises Ltd., [1979] C.T.C. 465; 79 D.T.C. 5399, the services rendered by the employees were rendered for several years without immediate payment on condition that the final remuneration was determined at the end of the year. ... M.N.R., [1981] C.T.C. 2005; 81 D.T.C. 21. Secondly, the Court held that the payment of the bonuses depended on whether the necessary funds were available. ...
TCC

Dias v. The Queen, 2021 TCC 85

The Appellants relied primarily on two cases. [27] The first is the 2005 decision of Chief Justice Bowman in Borys v. ... Graham” Graham J.   CITATION: 2021 TCC 85 COURT FILE NOS.: 2018-3473(IT)G 2018-3474(IT)G STYLES OF CAUSE: XAVIER DIAS v THE QUEEN WENDY DIAS v THE QUEEN PLACE OF HEARING: Toronto, Ontario DATES OF HEARING: October 19 and 20, 2021 REASONS FOR JUDGMENT BY: The Honourable Justice David E. ... Pniowsky Firm: Thompson Dorfman Sweatman LLP For the Respondent: François Daigle Deputy Attorney General of Canada Ottawa, Canada   ...

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