Search - connection

As long as a reasonable connection is shown between the cost of the service provided and the amount charged, that will suffice. ...

Generally, a person who is experienced in business and financial matters is likely to be held to a higher standard than a person with no business acumen or experience whose presence on the board of directors reflects nothing more, for example, than a family connection. ...

  [11]    Paragraph 8(1)(f) of the Income Tax Act provides as follows:   8(1) In computing a taxpayer’s income for a taxation year from an office or employment, there may be deducted such of the following amounts as are wholly applicable to that source or such part of the following amounts as may reasonably be regarded as applicable thereto:   …   (f) where the taxpayer was employed in the year in connection with the selling of property or negotiating of contracts for the taxpayer’s employer, and   (i) under the contract of employment was required to pay the taxpayer’s own expenses,   (ii) was ordinarily required to carry on the duties of the employment away from the employer’s place of business,   (iii) was remunerated in whole or part by commissions or other similar amounts fixed by reference to the volume of the sales made or the contracts negotiated, and   (iv) was not in receipt of an allowance for travel expenses in respect of the taxation year that was, by virtue of subparagraph 6(1)(b)(v), not included in computing the taxpayer’s income,   amounts expended by the taxpayer in the year for the purpose of earning the income from the employment (not exceeding the commissions or other similar amounts referred to in subparagraph 8(1)(f)(iii) and received by the taxpayer in the year) to the extent that those amounts were not   (v) outlays, losses or replacements of capital or payments on account of capital, except as described in paragraph (j),   (vi) outlays or expenses that would, by virtue of paragraph 18(1)(l), not be deductible in computing the taxpayer’s income for the year if the employment were a business carried on by the taxpayer, or   (vii) amounts the payment of which reduced the amount that would otherwise be included in computing the taxpayer’s income for the year because of paragraph 6(1)(e);   [12]    The Respondent does not take any issue with respect to whether the conditions set out in subparagraphs (i) to (iv) were satisfied but only raises two issues- whether the amount that was paid was a payment on account of capital and, if it was not on account of capital, whether the amount was paid for the purpose of earning the income from the Appellant’s employment with either BMO Nesbitt Burns or TD Waterhouse. ...

., 1999 CarswellNat 562, [1999] 2 C.T.C. 2677, D.T.C. 3502 allowing the deductibility of amounts paid in 1994 and 1995 by a common law husband in connection with a relationship which had ended in 1988. ...

" In Bronfman Trust, the Supreme Court referred, at page 51, to Rand, J. in Canada Safeway Ltd. (4.02(3)), at page 726 (C.T.C. 127-28, D.T.C. 5066): No doubt there is in fact a causal connection between the purchase of the stock and the benefits ultimately received; but the statutory language cannot be extended to such a remote consequence; it could be carried to any length in a chain of subsidiaries; and to say that such a thing was envisaged by the ordinary expression used in the statute is to speculate and not interpret. ...

This agreement constitutes the entire agreement between the parties hereto relating to the subject matter hereof and supersedes all prior and contemporaneous agreements, understandings, negotiations and discussions, whether oral or written, of the parties and there are no general or specific warranties, representations or other agreements by or among the parties in connection with the entering into of this agreement or the subject matter hereof except as specifically set forth herein. ...

., in circumstances different, in certain respects, from this case, held that: The fact that a corporation, carrying on an active business and holding certain property (i.e. investments) unrelated to the business, uses the income from the property in connection with the operation of the active business does not mean that the property is “incident to or pertains to” the active business. ...

Some employees of Bouilloire et Soudure Rive-Sud Inc. frequently worked for the appellant. [19]     In this connection, counsel for the respondent produced Exhibit I-7, which consists of invoices from one company to another showing considerable relationships between the appellant and Bouilloire. ...

Mike Adams testified that he had loaned $3,500 to Abraham Morigeau, a logging contractor, to assist him in the acquisition or repair of some machinery in connection with a business venture in which he was involved. ...

CyberPlan shall be paid a minimum fee (the "Minimum Fee") by Raconix in connection with licences granted by Raconix to its Customers as follows: (a) Initially, the Minimum Fee shall be calculated in accordance with Schedule "C". ...