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26 February 2015 CBA Roundtable

Roundtable notes
Selected Listed Financial Institution Rebate of PVAT Summary of Question CRA Response Q.29. ... Regent Trust Company Limited, (2005), J.L.Rev. 198 (CA) at para. 20). ... Recognition of nominee/prête-nom Summary of Question TVQ16-30/R1 « Contrat de prête-nom » states: “All persons may hold property of others under a nominee agreement. ...
FCA

Colubriale v. Canada, 2005 FCA 329

Canada, 2005 FCA 329   Date: 20051014 Docket: A-561-04 Citation: 2005 FCA 329   CORAM:       DESJARDINS J.A.                         NOËL J.A.                         PELLETIER J.A.     BETWEEN: GIUSEPPE COLUBRIALE Appellant and   HER MAJESTY THE QUEEN Respondent       Heard at Montréal, Quebec, on September 13, 2005. ... PELLETIER J.A.           Date: 20051014 Docket: A-561-04 Citation: 2005 FCA 329   CORAM:       DESJARDINS J.A.                         ...
TCC

Calce Holdings Ltd. v. The Queen, 2005 DTC 959, 2005 TCC 335

Signed at Ottawa, Canada, this 9th day of June, 2005. Brent Paris Paris, J. ... The Queen PLACE OF HEARING:                      Montreal, Québec DATE OF HEARING:                        September 9 and 10, 2004 REASONS FOR JUDGMENT BY:     The Honourable Justice Brent Paris DATE OF JUDGMENT:                     June 9, 2005 APPEARANCES: Counsel for the Appellant: Louis-Frédérick Côte and Josée Massicotte Counsel for the Respondent: Bernard Fontaine COUNSEL OF RECORD:        For the Appellant: Name:                                          Louis-Frédérick Côte and                                                           Josée Massicotte        Firm:                                           Mendelsohn Rosentzveig Shacter                                                           Montreal, Québec        For the Respondent:                     John H. ...
TCC

McGeachy v. The Queen, 2005 TCC 145 (Informal Procedure)

The Queen, 2005 TCC 145 (Informal Procedure)       Docket: 2003-4349(IT)I BETWEEN: NEIL W. ... Signed at Ottawa, Canada, this 21st day of February, 2005.       "A.A. ... Sarchuk   DATE OF JUDGMENT: February 21, 2005   APPEARANCES:   For the Appellant: The Appellant himself   Counsel for the Respondent: Nimanthika Kaneira   For the Third Party: The Third Party herself   COUNSEL OF RECORD:   For the Appellant:   Name: N/A   Firm: N/A   For the Respondent: John H. ...
FCA

Gaudreau v. Canada, 2005 FCA 388

Canada, 2005 FCA 388 Date: 20051116 Docket: A-80-05 Citation: 2005 FCA 388 CORAM:        NOËL J.A.                         SHARLOW J.A.                         PELLETIER J.A. BETWEEN: NORMAN GAUDREAU Appellant and HER MAJESTY THE QUEEN Respondent Heard at Ottawa, Ontario, on November 16, 2005. ... Date: 20051116 Docket: A-80-05 Citation: 2005 FCA 388 CORAM:        NOËL J.A.                         ...
Ruling

2006 Ruling 2005-0135761R3 - Class of German Arrangement & Treaty Benefits

GERMANCO is authorized by the German Federal Agency for Financial Services Supervision (the "Federal Agency") to operate as a capital investment company in relation to the establishment and operation of public funds like each Fund in accordance with the provisions of the Investment Companies Act, and as of October 1, 2005 of the Investment Act (Germany). ... FUND XXXXXXXXXX currently has a total of approximately XXXXXXXXXX institutional investors with an average investment of XXXXXXXXXX. ... As at XXXXXXXXXX, the value of FUND XXXXXXXXXX's net investments was XXXXXXXXXX, and XXXXXXXXXX% of FUND XXXXXXXXXX's investments consisted of liquid assets, which are invested so as to ensure that there is always sufficient liquidity available for future redemptions and to fund property acquisitions that are continually under active consideration by GERMANCO on behalf of FUND XXXXXXXXXX. 8. ...
Current CRA website

Income Tax Application Rules – Authorization to exercise powers or perform duties of the Minister of National Revenue

Income Tax Application Rules Authorization to exercise powers or perform duties of the Minister of National Revenue Pursuant to subsection 8(4) Footnote 1 of the Canada Revenue Agency Act Footnote 2, I hereby authorize persons holding the position of Deputy Commissioner, Assistant Commissioner and Deputy Assistant Commissioner in the Canada Revenue Agency, or a person authorized to perform the duties of one of those positions, to exercise or perform on behalf of the Minister of National Revenue the powers, duties and functions of the Minister under the Income Tax Application Rules Footnote 3 that I am authorized to exercise or perform pursuant to subsection 8(1) Footnote 1 of the Canada Revenue Agency Act Footnote 2; and authorize officers holding a position in the Canada Revenue Agency listed in the following Schedule, or a person authorized to perform the duties of that position, to exercise or perform on behalf of the Minister of National Revenue the powers, duties and functions of the Minister in respect of the provisions of the Income Tax Application Rules Footnote 3 that are listed in the Schedule and that I am authorized to exercise or perform pursuant to subsection 8(1) Footnote 1 of the Canada Revenue Agency Act Footnote 2. ... Original signed by Bob Hamilton, Commissioner of Revenue Date December 12, 2018 Schedule Income Tax Application Rules Section 23(5)- Paragraph (b) of the definition of “1971 receivables” May apportion between partners Field Positions Director, National Verification and Collections Centre Director, Tax Centre Director, Tax Services Office Assistant Director, National Verification and Collections Centre Assistant Director, Tax Centre Assistant Director, Tax Services Office Manager, Audit Team Leader, Audit Paragraph 26(18)(c) May extend the 36 month period to transfer farmland owned on December 31, 1971, to a child at death to a longer period that is considered to be reasonable in the circumstances Field Positions Director, National Verification and Collections Centre Director, Tax Centre Director, Tax Services Office Assistant Director, National Verification and Collections Centre Assistant Director, Tax Centre Assistant Director, Tax Services Office Manager, Audit Team Leader, Audit Footnotes Footnote 1 S.C. 1999, c. 17 Return to footnote1 referrer Footnote 2 S.C. 2005, c. 38, s. 35 Return to footnote2 referrer Footnote 3 R.S.C. 1985, c. 2 (5th Supp.) ...
TCC

Beaulieu c. La Reine, 2005 TCC 605

La Reine, 2005 TCC 605         Docket: 2001-3358(GST)G BETWEEN: RÉAL BEAULIEU, Appellant, and   HER MAJESTY THE QUEEN, Respondent.  ____________________________________________________________________ Appeal heard on August 5, 2005, at Montréal, Quebec. ... Signed a t Ottawa, Canada, this 24t h day of October 2005.   “P. R. Dussault” Dussault J.     ... Signed at Ottawa, Canada, this 18th day of October 2005.     “P. R. Dussault” Dussault J.       ...
TCC

Litowitz v. The Queen, 2005 DTC 1469, 2005 TCC 557

The Queen, 2005 DTC 1469, 2005 TCC 557 Docket: 2002-4744(IT)G BETWEEN: GERALD LITOWITZ, Appellant, and HER MAJESTY THE QUEEN, Respondent.____________________________________________________________________ Appeal heard on July 6 and 7, 2005, at Toronto, Ontario. ... Signed at Ottawa, Canada, this 6 th day of October, 2005. "D.G.H. ... Signed at Ottawa, Canada, this 6 th day of October 2005. "D.G.H. ...
TCC

Adams v. The Queen, 2005 DTC 636, 2005 TCC 237 (Informal Procedure)

The Queen, 2005 DTC 636, 2005 TCC 237 (Informal Procedure) Docket: 2004-1720(IT)I BETWEEN: JEFFREY ADAMS, Appellant, and HER MAJESTY THE QUEEN, Respondent. Appeal heard on February 23, 2005 at Calgary, Alberta Before: The Honourable Justice G. ... Signed at Ottawa, Canada this 8th day of April, 2005. "G. Sheridan" Sheridan, J. ...

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