Search - connection

The Queen, 2020 TCC 50 (Informal Procedure), aff'd 2022 FCA 115-- summary under Taxpayer Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Taxpayer an individual not within s. 2(1) or (3) was not a taxpayer who could generate a tuition tax credit An individual with no connection to Canada paid a lot in tuition fees while in attendance at U.S. universities prior to 2012 then, on immigrating to Canada, claimed his purported unused tuition tax credits as a deduction from Canadian tax. ...

He also found (at para. 133) that the various trips challenged by the ARQ had been established by Pelletier to be “necessary and incidental to trips that were solely commercial,” including some helicopter-ferrying to close down a fishing camp that had been used for client entertainment and the helicopter’s use in connection with training a pilot. ...

PVL purchased three pieces of equipment (a wheel loader, compact excavator, and hydraulic thumb) and used them exclusively for the handling of materials already gathered by a cable shovel in connection with the washing, sorting and crushing of the various products intended either for sale (as to about 73% of the products) or for use by PVL (as to the balance). ...

PVL purchased three pieces of equipment (a wheel loader, compact excavator, and hydraulic thumb) and used them exclusively for the handling of materials already gathered by a cable shovel in connection with the washing, sorting and crushing of the various products intended either for sale (as to about 73% of the products) or for use by PVL (as to the balance). ...

Their claim was granted in part, for damages suffered by the plaintiffs in connection with their dismissal. ...

Furthermore, she found that 9267 had not taken reasonable measures to pursue collection of its debt, including claiming under its security interest, and having its debt included in the debtor claims made against 9210 in connection with the receivership and bankruptcy proceedings. ...

Canada, 2022 FCA 115-- summary under Taxation Year Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Taxation Year Oceanspan principle indicates that a non-resident who does not compute income from any source for ITA purposes does not have a taxation year An individual with no connection to Canada paid significant tuition fees while in attendance at U.S. universities prior to 2012 then, on immigrating to Canada, claimed his “unused” tuition tax credits as a deduction from Canadian tax. ...

Canada, 2022 FCA 115-- summary under Subsection 104(13) Summary Under Tax Topics- Income Tax Act- 101-110- Section 104- Subsection 104(13) s. 104(13) requirement to compute the income of a non-resident trust with a Canadian beneficiary is an example of s. 250.1(a) application An individual with no connection to Canada paid significant tuition fees while in attendance at U.S. universities prior to 2012 then, on immigrating to Canada, claimed his “unused” tuition tax credits as a deduction from Canadian tax. ...

There is a direct and immediate connection between the production of potash and the subsequent sale or disposition of that potash. ...

Canada (Attorney General), 2022 FCA 158-- summary under Section 8 Summary Under Tax Topics- Other Legislation/Constitution- Charter (Constitution Act, 1982)- Section 8 FATCA-required disclosures do not constitute an unreasonable seizure contrary to the Charter Woods JA confirmed the rejection by the Federal Court of the position of two American citizens, who had had no significant connection with the U.S. since early childhood, that the information-reporting requirements in ITA Part XVIII (the “Impugned Provisions”) resulted in the unreasonable seizure of financial information belonging to U.S. persons in Canada, contrary to s. 8 of the Charter. ...