Search - connection

This question, in turn, rested upon determining whether the nature of the relationship between Telecom and the telephone companies its served (notably, Bell Canada, viewed as having a communications undertaking within federal jurisdiction), including the importance of the installation work done for Bell Canada and the physical and operational connections between the installation department and the core federal undertaking of Bell Canada, were such as to make the installation department part of that undertaking. ...

Vavilov, 2019 SCC 65, [2019] 4 S.C.R. 653-- summary under Ordinary Meaning Summary Under Tax Topics- Statutory Interpretation- Ordinary Meaning administrative decisions must have regard to the provision’s text, context and purpose In connection with noting that a reasonableness review of an administrative decision extends to a review of the administrative body’s approach to statutory interpretation, the Curt stated (at paras. 118, 120): Those who draft and enact statutes expect that questions about their meaning will be resolved by an analysis that has regard to the text, context and purpose, regardless of whether the entity tasked with interpreting the law is a court or an administrative decision maker. ...

., 2021 SCC 49, [2021] 3 S.C.R. 590-- summary under Treaties Summary Under Tax Topics- Statutory Interpretation- Treaties additional consideration in Treaty context of giving effect to the contractual bargain Before considering whether the taxpayer’s use of a capital gains exemption provision in the Canada-Luxembourg Treaty was an abuse under s. 245(4) given that the taxpayer was a conduit corporation rather than a corporation that had a significant economic connection to Luxembourg, Côté J stated (at paras. 29, 35-6): Like all statutes, tax legislation must be interpreted by conducting a “textual, contextual and purposive analysis to find a meaning that is harmonious with the Act as a whole” …. ...

Rothstein J. stated (at para. 56): The fact that the language of s. 248(10) allows either prospective or retrospective connection of a related transaction to a common law series and that such an interpretation accords with Parliamentary purpose, impels me to conclude that this interpretation should be preferred to the interpretation advanced by Copthorne [that "in contemplation of" is prospective only]. ...

In connection with finding that the equipment qualified in the taxpayer's hands as depreciable property, McLachlin J. stated (at para. 7): The fact that the assets produced revenue, as the reasons of L’Heureux-Dubé J. demonstrate, establishes that they continued to be used for the purpose of producing income, avoiding the effect of s. 13(7)(a) and the exclusion under Regulation 1102(1)(c). ...

The Minister argued that Lavallee applied where law enforcement officials were seeking evidence of criminal wrongdoing, and not in connection with a regulatory compliance regime. ...

The Minister argued that Lavallee applied where law enforcement officials were seeking evidence of criminal wrongdoing, and not in connection with a regulatory compliance regime. ...

It also provided an unqualified audit opinion in connection with Livent’s 1997 financial statements following an audit thereof which it completed in April 1998. ...

MacDonald did not sell his … shares immediately to offset his losses under the forward contract does not sever this connection” (para. 42) “[C]ash settled forward contracts and forward contracts settled by physical delivery are economically equivalent and treating them differently for tax purposes would create ‘an unjustified artificial distinction’.” ...