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Results 151 - 160 of 356 for connection
SCC
R.S. v. P.R., 2019 SCC 49, [2019] 3 SCR 643
But the fact that a dispute has been submitted to a foreign forum does not guarantee that the foreign forum necessarily has a close connection with the dispute (Goldstein and Groffier, at No. 126). ... Glenn, “Droit international privé”, in La réforme du Code civil, vol. 3, Priorités et hypothèques, preuve et prescription, publicité des droits, droit international privé, dispositions transitoires (1993), 669, at p. 746. (3) Application of the Law to the Facts of the Case (a) Preventing Abusive Forum Shopping (i) Existence of Real and Substantial Connections With Belgium [181] The Court of Appeal found that there were [translation] “real and substantial connections” between the husband and Belgium; it added that the husband’s choice of the Belgian court had not resulted from abusive forum shopping (para. 146). ... Moreover, it is consistent with the findings of the Belgian court and the Cour d’appel de Bruxelles, which also noted the existence of numerous connections with Belgium and rejected the wife’s argument regarding alleged abusive forum shopping on the husband’s part: A.R., vol. ...
SCC
Ludco Enterprises Ltd. v. Canada, 2001 DTC 5505, [2001] 2 S.C.R. 1082, 2001 SCC 62
Finally, the respondent argues that there should be no award of special costs in this case as there is no evidence of misconduct by the respondent in connection with the litigation. ... As noted above, the focus of the inquiry in this case is clearly on the third element, namely, whether the borrowed money was used for the purpose of earning non-exempt income from business or property. 44 In this connection, Dickson C.J., writing for the Court in Bronfman Trust, supra, closely analysed the third element of the interest deductibility provision and classified the various possible uses of borrowed money as: eligible and ineligible, original and current, and direct and indirect. ... Therefore, it is perfectly consistent with the language of s. 20(1)(c)(i) that a taxpayer who uses borrowed money to make an investment for more than one purpose may be entitled to deduct interest charges provided that one of those purposes is to earn income. 51 In this connection, the adjectives that have been heretofore used by courts to characterize the requisite purpose in s. 20(1)(c)(i), such as “ bona fide ”, “actual”, “real” or “true”, are to my mind ultimately useful only when describing whether the transaction at issue was a mere sham or window dressing designed to obtain the benefit of interest deductibility. ...
SCC
Markevich v. Canada, 2003 DTC 5185, 2003 SCC 9, [2003] 1 SCR 94
They import such meanings as “in relation to”, “with reference to” or “in connection with”. The phrase “in respect of” is probably the widest of any expression intended to convey some connection between two related subject matters. In the context of s. 32, the words “in respect of” require only that the relevant proceedings have some connection to a cause of action. 27 A “cause of action” is only a set of facts that provides the basis for an action in court: see Letang v. ...
SCC
Wilson v. Minister of National Revenue, 55 DTC 1065, [1955] CTC 87, [1955] S.C.R. 352
Wilson and the goodwill thereof, all goods, stock-in-trade, furniture, machinery, store fittings and plant together with the benefit of all contracts subsisting in relation to the said business, all book debts owing to me in connection with said business and all securities for money, cash and money in bank to the credit of the said business subject to my said son complying with the following terms, namely: (d) Entering into a covenant under seal with my wife binding himself and his executors and administrators to pay to her during her lifetime the sum of $500.00 each and every month on the first day thereof in advance, the first of such payments to be made on the 1st day of the month next following my death: (e) Entering into a covenant under seal with my said wife and my Trustees, binding himself and his executors and administrators, whereby he shall covenant that during the lifetime of my wife or until the same be sold, whichever event shall the earlier happen, he or they will pay all taxes, local improvement charges, insurance premiums and expenses of all ordinary repairs to the upkeep of the fabric of my residence known as number 811 St. ... Wilson and the goodwill thereof, all goods, stock-in-trade, furniture, machinery, store fittings and plant, together with the benefit of all contracts subsisting in relation to the said business, all book debts owing to me in connection with the said business and all securities for money, cash and money in bank to the credit of the said business.’’ subject to his complying with the following terms: paying all succession and probate duties chargeable against the estate and the legatees in respect of the bequests to himself, his mother and five named employees to whom a total of $2,000 was given, assuming and discharging all the debts and liabilities of the business and the premises referred to and entering into a covenant with his mother, binding himself to pay her $500 on the first day of each month during her lifetime, and a further covenant with her and with the trustees to pay all taxes, insurance premiums and the expenses of upkeep of the testator’s former home at 811 St. ... Section 6 of the Income War Tax Act reads in part as follows: “6. (1) In computing the amount of the profits or gains to be assessed, a deduction shall not be allowed in respect of (a) disbursements or expenses not wholly, exclusively and necessarily laid out or expended for the purpose of earning the income; (b) any outlay, loss or replacement of capital or any payment on account of capital or any depreciation, depletion or obsolescence, except as otherwise provided in this Act; (c) the annual value of property, real or personal, except rent actually paid for the use of such property, used in connection with the business to earn the income subject to taxation.” ...
SCC
The Queen v. Beaver Lamb and Shearing Co., [1960] SCR 505
Now, would you be good enough to tell me just what you did in that connection? ... And what position did he take in regard to your representations in that connection? ... In this regard it seems appropriate to refer to what was said by Macdonald J.A., speaking in the same connection on behalf of the Court of Appeal of British Columbia in Vancouver Growers Limited v. ...
SCC
Canadian Pacific Air Lines Ltd. v. British Columbia, [1989] 1 SCR 1133
In the latter case, there was in his view a sufficiently substantial connection to satisfy the constitutional requirement in s. 92(2) , Constitution Act, 1867 , that the taxed subject must be "within the province" before it can be taxed. Once it was decided that there was a sufficient connection to attract the tax, there was no objection to the province measuring the amount of the tax on the basis of miles travelled in the airspace over the province as compared to total miles travelled by the aircraft. ... This is confirmed, I think by the words used in the provision, and especially if one considers them in connection with the purported application of the provision to the facts of this case. ...
SCC
R. v. Nolet, 2010 SCC 24, [2010] 1 SCR 851
The lapse of about two hours between the roadside arrest and the search of the trailer’s secret compartment is not significant and did not undermine the close causal and spatial connection between the arrest and the search. ... [50] The lapse of about two hours between the roadside arrest and the search of the trailer’s secret compartment is not significant and did not, in my view, undermine the close causal and spatial connection between the arrest and the search. ... However, the basis of the warrantless search was not “exigent circumstances” but connection or relatedness, i.e. to trigger the common law authority to search for evidence of the crime to which the arrest related: Cloutier v. ...
SCC
Saulnier v. Royal Bank of Canada, 2008 SCC 58, [2008] 3 SCR 166
[30] Some analytical comfort may be drawn in this connection from the observations of R. ... In this connection the property in question is the fish harvest. [35] Of course, the holder’s rights under a fishing licence are limited in time, place and the manner of their exercise by the Fisheries Act and Regulations. ... There is no necessary connection between proprietary status and commercial value. ...
SCC
International Air Transport Association v. Instrubel, N.V., 2019 SCC 61, [2019] 4 SCR 469
The record does not show that Instrubel has any connection with or business in Quebec or Canada. [7] The appellants include the Republic of Iraq (“Iraq”) and three parties that were involved in arbitration proceedings against Instrubel: the Ministry of Industry of the Republic of Iraq, the Ministry of Defence of the Republic of Iraq and the Salah Aldin State Establishment. [1] The Iraqi entity most relevant to these appeals is the Iraqi Civil Aviation Authority (“ICAA”), the agency responsible for the regulation of Iraq’s airspace. [8] The final appellant, the International Air Transport Association (“IATA”), is the global trade association for the international air transport industry. ... Most importantly, IATA had no connection whatsoever with the arbitration proceedings. [12] A decade later, on March 11, 2013, Instrubel filed in the Quebec Superior Court a Motion for the Homologation, Recognition and Enforcement of Arbitration Awards Made Outside Quebec, alleging that it had “only recently learned that the Republic of Iraq possesses significant assets in the Province of Quebec”: A.R., vol. ... Issue [25] These appeals raise the question of whether the Quebec Superior Court has jurisdiction to issue a writ of seizure before judgment by garnishment where the garnishee is located in the province but the property is located outside the province, and where the parties and the transaction giving rise to the seizure have no connection with Quebec. ...
SCC
Canada (Attorney General) v. Federation of Law Societies of Canada, 2015 SCC 7, [2015] 1 SCR 401
(Garson J.A. concurring) held that clients’ liberty interests are not engaged by these provisions because the causal connection between the provisions and any potential loss of clients’ liberty is too remote ... The Attorney General submits, however, that Lavallee does not dictate the outcome here: the Court in that case was only considering the question of what safeguards are constitutionally required in situations where law enforcement officials are seeking evidence of criminal wrongdoing, not as here, in connection with an administrative law regulatory compliance regime ... The rational connection does not impose a particularly onerous threshold: Little Sisters Book and Art Emporium v. ...