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TCC

Cathelle Inc. v. The Queen, 2005 DTC 858, 2005 TCC 360

Expenses incurred by the Appellant and rebilled to Hollowforms: Wages and Benefits $234,708.08 Building and Equipment     Repairs 10,425.85 Small Tools 17,180.31 Utilities and Telephone 22,866.12 Insurance 6,425.40 Convention Booths and costs 1,913.27 Travel 1,771.06 Office Equipment Rent 1,883.44 Total $297,173.53 2.) ...
TCC

Barat v. M.N.R., 91 DTC 1097, [1991] 2 CTC 2360 (TCC)

In The Concadoro, [1916] 2 A.C. 199, the Privy Council looked at the expression "force majeure" and whether "force majeure” was available to "an enemy merchant ship" seeking an unconditional pass under article 1 of the Hague Convention No. ...
TCC

Giguere v. The Queen, 2005 DTC 646, 2005 TCC 257

(b) the personal property of an Indian or a band situated on a reserve.... [5]      Paragraph 81(1)(a) of the Income Tax Act reads as follows: Amounts not included in income 81.(1) There shall not be included in computing the income of a taxpayer for a taxation year, Statutory exemptions (a) an amount that is declared to be exempt from income tax by any other enactment of Parliament, other than an amount received or receivable by an individual that is exempt by virtue of a provision contained in a tax convention or agreement with another country that has the force of law in Canada.... [6]      The Appellants' opening position is that because of what they describe as their family's history of logging on the Crown land from which they were hauling logs between 1994 and 1998, the Crown land is (in the Appellants' words) "as a reserve" and therefore comes within the meaning of "on a reserve" in paragraph 87(1)(b) of the Indian Act. ...
TCC

Simon-Carves of Canada Ltd. v. MNR, 89 DTC 98, [1989] 1 CTC 2149 (TCC)

The respondent further says that in these circumstances the appellant has been properly assessed for withholding tax of $58,315 pursuant to paragraph 212(2)(a); subsections 215(1) and 215(6) of the Act and Article 10 of the Canada-United Kingdom Income Tax Convention. ...
TCC

Williams Gold Refining Co. of Canada v. The Queen, 2000 DTC 1829 (TCC)

Expenses incurred by the Appellant and rebilled to Hollowforms: Wages and Benefits $234,708.08 Building and Equipment Repairs 10,425.85 Small Tools 17,180.31 Utilities and Telephone 22,866.12 Insurance 6,425.40 Convention Booths and costs 1,913.27 Travel 1,771.06 Office Equipment Rent 1,883.44 Total $297,173.53 2.) ...
TCC

Chagnon v. The Queen, 2011 DTC 1205 [at at 1216], 2011 TCC 268

Pièce 3  : Convention d’octroi d’options d’achat d’actions du 19 janvier 2000.   3.                   ...
TCC

Wagner v. The Queen, 2012 TCC 59

"suppl y " means, subject to sections 133 and 134, the provision of property or a service in any manner, including sale, transfer, barter, exchange, licence, rental, lease, gift or disposition;   "taxable supply" means a supply that is made in the course of a commercial activity;               "acquéreur"               a)   Personne qui est tenue, aux termes d'une convention portant sur une fourniture, de payer la contrepartie de la fourniture;   …   "fourniture" Sous réserve des articles 133 et 134, livraison de biens ou prestation de services, notamment par vente, transfert, troc, échange, louage, licence, donation ou aliénation.   ...
TCC

Nahwegahbow v. The Queen, 2011 TCC 296 (Informal Procedure)

Relevant legislative provisions   Income Tax Act   81. (1) Amounts not included in income – There shall not be included in computing the income of a taxpayer for a taxation year,   (a) Statutory exemptions [including Indians] – an amount that is declared to be exempt from income tax by any other enactment of Parliament, other than an amount received or receivable by an individual that is exempt by virtue of a provision contained in a tax convention or agreement with another country that has the force of law in Canada;   Indian Act   87(1) Property exempt from taxation – Notwithstanding any other Act of Parliament or any Act of the legislature of a province, but subject to section 83 and section 5 of the First Nations Fiscal and Statistical Management Act, the following property is exempt from taxation:   (a) the interest of an Indian or a band in reserve lands or surrendered lands; and   (b) the personal property of an Indian or a band situated on a reserve.                                                                                                           ...
TCC

Agostini v. The Queen, 2009 TCC 87

The appellant also filed an ExpoCard showing that he attended a convention in New Orleans during the period from January 9 through January 12, 2002 (Exhibit A-2). ...
TCC

Neilson v. The Queen, 2007 TCC 512

In NLG’s Business Plan 2000, marketing was described as consisting of:  - direct calling – print advertising – direct mail advertising – word of mouth – community involvement generating networking opportunities – conference and convention participation and presentation – permission based email marketing – online advertising – web based word of mouth – cross promotion ...

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