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SCC
Reference re the jurisdiction of the Tariff Board of Canada, [1934] SCR 538
In connection with these inquiries or investigations, the Board is given the power of summoning witnesses and of taking evidence. ... Moreover, the decisions of the Tariff Board which led to the present reference have no apparent connection with s. 54. ... In that connection, the local appraisers, when giving their decision, are exactly on a par with the Dominion appraiser or the Board. ...
SCC
Her Majesty the Queen v. Mead Johnson of Canada Ltd., [1966] CTC 201, 66 DTC 5175
“To pay out of the capital of the residue of my estate my just debts, funeral and testamentary expenses and all estate, legacy, succession and inheritance taxes or duties, whether imposed by or pursuant to the law of any domestic or foreign jurisdiction whatsoever, that may be payable by any beneficiary of this my Will or any Codicil hereto in connection with the property passing (or deemed to pass by any governing law) on my death...” 2. ... I GIVE, DEVISE AND BEQUEATH the whole of iny property of every nature and kind and wheresoever situate including any property over which I may have any general power of appointment to my said Trustees upon the following trusts, namely: a) To pay out of the capital of the residue of my estate my just debts, funeral and testamentary expenses and all estate, legacy, suecession and inheritance taxes or duties, whether imposed by or pursuant to the law of any domestic or foreign jurisdiction whatsoever, that may be payable by any beneficiary of this my Will or any Codicil hereto in connection with the property passing (or deemed to pass by any governing law) on my death or in connection with any insurance and/or annuities on my life or in connection with any insurance and/or annuities on my life or in connection with any gift or benefit given or provided by me either in my lifetime to or for any such beneficiary, or by survivorship,. or by this my Will or any Codicil thereto, or to or for the benefit of any beneficiary of any trust or settlement created by me during my lifetime, and whether such taxes and duties be payable in respect of estates or interests which fall into possession at my death or at any subsequent time; and I hereby authorize my Trustees to commute or prepay any such taxes or duties. ...
SCC
Ontario Hydro v. Ontario (Labour Relations Board), [1993] 3 SCR 327
Only those actually employed on or in connection with facilities for the production of nuclear energy are federally regulated. ... Only those employees actually employed on or in connection with facilities for the production of nuclear energy are federally regulated. ... The danger, rather, lay in the possible transformation of these enterprises into purely federal undertakings by reason of their connection or extension beyond the province. ...
SCC
Wrights' Canadian Ropes Limited v. The Minister of National Revenue, [1946] SCR 139
In connection with the appeal certain remarks in The King [Page 154] v. ... The discretion was exercised not only in connection with income tax but also excess profits tax, as section 8 of The Excess Profits Tax Act, 1940, provides:— 8. ... This same witness was also asked: "This $7,500, is that the amount allowed to you by the Munitions and Supply in connection with your contracts? ...
SCC
Wrights’ Canadian Ropes Limited v. Minister of National Revenue, [1946] CTC 73
In connection with the appeal certain remarks in The King v. Noxzema Chemical Company of Canada, Ltd., [1942] Canada Tax Cases 21, may be reiterated and emphasized. ... The discretion was exercised not only in connection with income tax but also excess profits tax as section 8 of the Excess Profits Tax Act, 1940, provides:— “8. ... This same witness was also asked, "‘this $7,500.00, is that the amnunt allowed to you by the Munitions and Supply in connection with your contracts?” ...
SCC
Miron and Frères Ltd. v. Minister of National Revenue, 55 DTC 1109, [1955] CTC 182, [1955] SCR 679
In that connection it is necessary to refer to subsection (5) of Section 127 of the Act by which u (5) For the purposes of this Act, (a) a corporation and a person or one of several persons by whom it is directly or indirectly controlled shall, without extending the meaning of the expression ‘to deal with each other at arm’s length’ be deemed not to deal with each other at arm’s length.’’ ...
SCC
Vina-Rug (Canada) Limited v. Minister of National Revenue, 68 DTC 5021, [1968] CTC 1, [1968] SCR 193
McGilvery, who collectively owned more than 50% of the shares of Stradwick’s Limited, had at all material times a sufficient common connection as to be in a position to exercise control over Stradwick’s Limited and therefore constituted a “‘group of persons’’ within the meaning of subsection (4) of Section 39 of the Income Tax Act. ...
SCC
Minister of National Revenue v. Tara Exploration and Development Company Limited,, [1972] CTC 328, 72 DTC 6288
In this connection — (i) An enterprise of one of the territories shall not be deemed to have a permanent establishment in the other territory merely because it carries on business dealings in that other territory through a bona fide broker or general commission agent acting in the ordinary course of his business as such; (ii) The fact that an enterprise of one of the territories maintains in the other territory a fixed place of business exclusively for the purchase of goods or merchandise shall not of itself constitute that fixed place of business a permanent establishment of the enterprise; (iii) The fact that a company which is a resident of one of the territories has a subsidiary company which is a resident of the other territory or which carries on a trade or business in that other territory (whether through a permanent establishment or otherwise) shall not of itself constitute that subsidiary company a permanent establishment of its parent company. ...
SCC
M.F.F. Equities Ltd. v. Her Majesty the Queen, [1969] CTC 291
It must be noted however that this designation does not appear to be used in connection with retail sales. ...
SCC
Minister of National Revenue v. Edgeley Farms Limited, [1969] CTC 313, 69 DTC 5228
., in connection with the development of the property; (b) to purchase the property at any time up until December 31, 1967 for $875,000; (c) to renew the option to purchase for a further eight years provided he arranged for the respondent a new first mortgage for at least $300,000 bearing interest at 7 per cent per annum; (d) to exercise the option to purchase from time to time with regard to various parcels of not less than 10 acres, on the basis of paying $2,500 per acre and the rent under the lease being reduced by $150.00 for each acre purchase. ...