Search - connection

. … [T]he connection between the use of the Services and the employee’s employment activities is even more tenuous when the employee’s family member receives the supply. ...

., cancellation) of the non-compete The taxpayer made a series of demands for parties to a non-compete agreement (that it had received in connection with its acquisition of a business) to comply with the agreement and, following negotiations and before the commencement by it of an action, it was agreed that it would be paid a lump sum in consideration for the cancellation of the non-compete agreement. ...

Canada, 2024 FCA 192, leave granted 22 May 2025 (41643)-- summary under French and English Version Summary Under Tax Topics- Statutory Interpretation- French and English Version “as a consequence of” interpreted in light of the shared meaning of the French and English versions In finding that the phrase “as a consequence of” in s. 161(7)(b)(iv) required a causal connection, Woods JA stated (at paras. 32-34): [B]oth the English and French versions of the proviso imply a causal element. ...

The case law requires a rational connection between the reasonably determined risk and the amount of the reserves. ...

Expense- Financing Expenditures refinancing fees not incurred in the course of earning income The taxpayers incurred various expenditures in connection with retiring existing bonds before maturity and issuing replacement bonds at a lower rate of interest and with less onerous conditions as to payment, including the payment of redemption premiums, disbursements on account of exchange, discounts paid to the underwriters on the issuance of the new bonds, and legal and printing expenses. ...

Regarding QSTA s. 199(c) (similar to ETA s. 169(1) – B(c)), St-Joseph argued based on QSTA s. 42.5 (similar to ETA s. 141.1(3)(a)) that it had incurred the costs “in connection with the … termination of a commercial activity” of it, so that such costs were deemed to have been incurred in the course of its commercial activity. ...

Turning to QSTA s. 199(c) (similar to ETA s. 169(1) – B(c)), she went on to reject an argument of St-Joseph based on QSTA s. 42.5 (similar to ETA s. 141.1(3)(a)) that it had incurred the costs “in connection with the … termination of a commercial activity” of it, so that such costs were deemed to have been incurred in the course of its commercial activity. ...

St-Joseph argued based on the QSTA equivalent of ETA s. 141.1(3)(a) that it had incurred the costs “in connection with the … termination of a commercial activity” of it, so that such costs were deemed to have been incurred in the course of its commercial activity. ...

St-Joseph argued based on the QSTA equivalent of ETA s. 141.1(3)(a) that it had incurred the costs “in connection with the … termination of a commercial activity” of it, so that such costs were deemed to have been incurred in the course of its commercial activity. ...

The Queen, docket 98-2383(IT)G (TCC)-- summary under Subsection 245(3) Summary Under Tax Topics- Income Tax Act- Section 245- Subsection 245(3) GAAR not to be used to fill in gaps of specific anti-avoidance provisions The taxpayer, who owned a portion of the shares of the holding ("GH") which, in turn, owned an operating company ("GBC") utilized the enhanced capital gains exemption in connection with the sale of a cement plant operated by GBC through the following transactions: the taxpayer and the other shareholders of GH transferred a portion of their shares of Holdings to a newly-incorporated company ("Newco") in consideration for shares of Newco having a value of $500,000; GBC paid a dividend-in-kind of most of the cement plant assets (having a value of $1 million) to Holdings; Holdings redeemed the common shares held in its capital by Newco by transferring to Newco the assets it had received from GBC; and the shareholders of Newco's sold their interests in Newco to the purchaser (who also purchased the remaining cement-plant assets directly from GBC). ...