Search - 2005年 抽纸品牌 质量排名

La Reine, 2005 TCC 315 (Informal Procedure)         Docket: 2004-3217(IT)I BETWEEN: BRUNO LAPLANTE, Appellant, and   HER MAJESTY THE QUEEN Respondent.   ... Signed at Ottawa, Canada, this 1st day of December 2005.       "Paul Bédard" Bédard J.   ...   [15]     For these reasons, the appeals are allowed.   Signed at Ottawa, Canada, this 1st day of December 2005.           ...

The Queen, 2005 DTC 1478, 2005 TCC 723         Docket: 2002-479(IT)G 2002-4202(IT)G BETWEEN: UNIVAR CANADA LTD., (formerly Vopak Canada Ltd. ... Signed at Ottawa, Canada, this 3 rd day of November 2005.     “R.D. Bell” Bell, J.           ... Signed at Ottawa, Canada, this 3 rd day of November 2005.     “R.D. Bell” Bell, J.   ...

  [9]               The Respondent stated in paragraph 14 of the Amended Reply that it had relied on the following assumptions of fact in making its decision:   (a)     the Appellant is in the Business of providing financial services and insurance (the “Business”);   (b)     the Appellant’s fiscal year is from January 1 to December 31;   (c)     the Appellant’s shareholders and their percentages of holdings are:   2006 ·   James Saint                  51% ·   Saint Family Trust         49% 2007 to present ·   James Saint                  100%;   (d)     James Saint is the President of the Business;   (e)     for the relevant period, the Workers were employed by the Appellant under a contract of service;   (f)      the Workers’ positions are as follows:   ·   Shannon MacDonald    Executive Assistant ·   Kevin Lundy                 Sales and Administration ·   Nicolas Anstis              Financial Advisor;   (g)     the Appellant had five employees in 2006, five in 2007 and four in 2008;   (h)     the Appellant set up a trust (“the Trust”) on January  1, 2006 by entering into an agreement;   (i)      the Trustees of the Appellant’s “Trust” are James Saint, James McIntyre and Daryl Phippan;   (j)      James McIntyre and Daryl Phippan were not active in the management of the funds;   (k)     the realized net income is to be allocated to the Participants prior to the end of the year via written direction from the Board of Directors;   (l)      pursuant to the Appellant’s Resolutions, the allocations were to be as follows:   ·   Resolution dated December 23, 2006, the amount of $386,146.86 are [sic] to be paid by December 31, 2006 –   Shannon MacDonald:            $47,026 –   Kevin Lundy:             $33,369 –   James Saint:                           $233,740 –   Nicolas Anstis:                       $72,010 ·   Resolution dated December 23, 2007, the amount of $163,736.88 are [sic] to be paid by December 31, 2007 –   Shannon MacDonald:            $52,979 –   Kevin Lundy:             $38,646 –   James Saint:                           $0.00 –   Nicolas Anstis:                       $72,110   (m)    the Workers received the following T4 employment income from the Appellant:   Name 2005 2006 2007 Nicolas Anstis $40,499 $6,153 $64,356 Kevin Lundy $34,384 $5,000 $4,500 Shannon MacDonald $46,499 $6,384 $4,500 James Saint $230,000 $3,975 $294,406   (n)     in 2006, the Workers received an annual nominal amount between $3,975 and $6,384 on which deductions were taken through the Appellant’s regular payroll;   (o)     in 2007, the Workers received an annual nominal amount between $1,500 and $4,500 on which deductions were taken through the Appellant’s regular payroll;   (p)     the Workers received additional income from the Appellant as follows:   Name 2006 2007 Nicolas Anstis $124,964 $72,110 Kevin Lundy $33,369 $38,646 Shannon MacDonald $47,026 $52,979 James Saint $280,000 $0.00 Total $485,359 $163,736.88   (q)     in 2006, the percentage of additional income compared to T4 income was as follows:   Name 2006 T4 income 2006 additional income Percentage Shannon MacDonald $6,384.62 $47,026.50 726.56% Kevin Lundy $5,000 $33,369 667.38% James Saint $3,975.00 $280,000 7,044.03% Nicolas Anstis $6,153.85 $124,964.37 2,030.67%   (r)     in 2006 2007, the percentage of additional income compared to T4 income was as follows:   Name 2006   2007 T4 income 2006 2007 additional income Percentage Shannon MacDonald $4,500.00 $52,979.75 1,177.33% Kevin Lundy $4,500.00 $38,646.25 858.81% James Saint $294,406.00 $0.00 0.00% Nicolas Anstis $64,356.76 $72,110.88 112.05%   (s)     the payments referred to in paragraph s (q) and (r) above were not based on any determined formula, and contributions were calculated on an ad hoc basis;   (t)      only Nicolas Anstis, Kevin Lundy, Shannon MacDonald and James Saint received additional income from the Appellant in 2006 and 2007;   (u)     the Appellant reported on its financial Balance Sheet, Retained Earnings, as follows:   2005 $1,141,436 2006 $906,921 2007 $1,230,669   (v)     the Appellant reported on its financial Income Statement, Profit, as follows:   2005 $229,866 2006 $371,313 2007 $492,699   (w)    the Appellant reported on its financial Income Statements and on its corporate returns the amounts paid to the Workers as salaries and wages;   (x)     the Workers were paid all income through a bank account number 1093656 in the name of “J.R. ... Saint & Associates Insurance Agencies Ltd.” bank account were as follows:   Years Contributions Withdrawals 2005 2006 $479,233.32 $482,427.18 2006 2007 $185,000.00 $161,657.63 2007 2008 $35,200.00 $35,163.37   (bb)   none of the funds contributed to the J.R. ... Beck     Counsel for the Respondent: Marla Teeling   COUNSEL OF RECORD:          For the Appellant:                             Name:                      Gordon D. ...

The Queen, 2005 TCC 368 (Informal Procedure)       Docket: 2004-3839(IT)I   BETWEEN: H.L.S. ... Signed at Ottawa, Canada, this 1st day of June 2005.       "Louise Lamarre Proulx" Lamarre Proulx J.   ...   [19]     The appeal is accordingly dismissed.     Signed at Ottawa, Canada, this 1st day of June 2005.       ...

Signed at Ottawa, Canada, this 24th day of October, 2005.         "Paul Bédard" Bédard J.       ... REASONS FOR JUDGMENT   Bédard J.   [1]     These appeals filed under the general procedure were heard in Chicoutimi, Quebec, on March 16, 2005. ... Signed at Ottawa, Canada, this 24th day of October 2005.           "Paul Bédard" Bédard J.   ...

., 2005 TCC 570         Docket: 2005-961(EI) BETWEEN: GILLES HUDON, Appellant, and             THE MINISTER OF NATIONAL REVENUE, Respondent.   ... Signed at Ottawa, Canada, this 26th day of August 2005.     "Alain Tardif" Tardif J.     ...   [22]     Consequently, the appeal is dismissed.   Signed at Ottawa, Canada, this 26th day of August 2005.     ...

Signed at Ottawa, Canada, this 5th day of August 2005.       "G. ... Sheridan   DATE OF JUDGMENT: August 5, 2005   APPEARANCES:   Counsel for the Appellant: Scott I. ...

Signed at Vancouver, British Columbia, this 25th day of February 2005.     ...       [29]     The appeal is dismissed, with costs.     Signed at Vancouver, British Columbia, this 25th day of February 2005.       ... Little   DATE OF REASONS FOR ORDER AND SUPPLEMENTARY JUDGMENT:       February 25, 2005   APPEARANCES:   Counsel for the Appellant: Timothy W. ...

The Queen, 2005 TCC 659 (Informal Procedure)           Docket: 2004-4291(GST)I,   BETWEEN: HUBERT J. ... Signed at Ottawa, Canada, this 12th day of October, 2005.     " Campbell J. ...

The Queen, 2005 TCC 277       [OFFICIAL ENGLISH TRANSLATION]   Docket: 2001-2505(IT)G BETWEEN: GUY TREMBLAY, Appellant, and   HER MAJESTY THE QUEEN, Respo ndent.____________________________________________________________________ Appeals heard on March 18, 2005 at Québec, Quebec   Before: The Honourable Justice Paul Bédard   Appearances:   Counsel for the Appellant: Marc Bouchard     Counsel for the Respondent: Martin Gentile____________________________________________________________________   JUDGMENT             The appeals from assessments made pursuant to the Income Tax Act for the taxation years 1991, 1992, 1993, 1994 and 1995 are dismissed, with costs, in accordance with the attached Reasons for Judgment.   Signed at Ottawa, Canada, this 24th day of  October 2005.       « Paul Bédard » Bédard J.           ...   [14]     Therefore the appeals are dismissed with costs.   Signed at Ottawa, Canada, this 24th day of October 2005. ...