Search - connection

Bowey, and with another accounting firm, with a view to obtaining tax advice in relation to the appellant’s business, not only in connection with the joint venture, but on a comprehensive basis. ... The human resource costs related to the expatriate connection and the technology cost related to the access that they had to technology. ...

Subsection 96(8) mandated the lower of cost or market in connection with a Canadian resident partner becoming a member of a foreign partnership. ...   [59]     I allow the appeal only in connection with the penalties imposed by CCRA, referring the matter back for reconsideration and reassessment on the basis that penalties are to be reduced to $100 each for 1992, 1993 and 1994. ...

Harvey has separately made a claim for an internet connection.   [52]         While I do not accept the figure put forward for home office use by Mr.  ... Harvey’s credibility, my specific view of his credibility in respect of the alleged 2003 trip to Victoria, the lack of any documentation supporting the 2003 and 2004 travel expenses, the lack of any documentary evidence of the existence of the conferences or seminars and the connection between the Toronto stopover and a family vacation, I am not prepared to allow Mr. ...

It is quite clear that marketing campaigns cannot create lasting advantages and must necessarily be recurrent. [43]     In conclusion, regardless of whether the sales outlets were "corporate" stores or franchised stores, the advantage that was sought and could reasonably be obtained was an enduring connection to Rona's business structure. [44]     The fact that Rona acquired an ownership interest in Inovaco's capital stock merely for a short period is not relevant. ... They were losses incurred in connection with a capital venture.... I think it is clear that an expenditure incurred for the purpose of enabling a taxpayer to decide whether a capital asset should be acquired is an outlay or payment on account of capital.... [14] Counsel for the plaintiff relied on the judgments of Noël A.C.J. in Bowater Power Company Limited v. ...

I told Pertamina that I knew of potential sources of such funds and I travelled from Indonesia to Calgary and to San Francisco and Houston, for example, in connection with this Project ... I have no doubt that Roth had a considerable accumulation of knowledge as a result of his various business activities and connection with those expenses, which knowledge was of great interest to Pac-Rim LNG Joint Venture, leading ultimately to the sale of the five percent interest in the existing project to Pac-Rim LNG Inc, Bechtel Enterprises International LTD, Phillips Petroleum Canada Ltd and Daewoo Corporation.  ...

Notwithstanding the provisions of paragraph 2: (a)     copyright royalties and other like payments in respect of a deduction of any literary, dramatic, musical or artistic work (but not including royalties in respect of motion picture films and work on film, videotape or other means of reproduction for use in connection with television broadcasting; and (b)     royalties for the use of or the right to use computer software or any patent or for information concerning industrial, commercial or scientific experience (but not including any such information provided in connection with the rental or franchise agreement)          arising in a State and paid to a resident of the other State who is the beneficial owner of the royalties shall be taxable only in that other State ...

Counsel pointed out that it is not necessary that the outlay or expense should have resulted in a particular income, that it be in the year that it was expended or that there be a casual connection between the expenditure and a receipt. ... It is true that the expenditure need not produce a profit but in this case there was no connection between the expenditure in question and the Appellants’ other businesses. ...

The expert business skills, connections and profile of the persons involved at CMM were evident. ... Even if that were not the case, CMM had an enforceable legal right, reflected in tabs 19, 20, and 21 of Exhibit A-l, to call upon its major shareholders for up to $3,000,000 in connection with its guaranteed commitment to the Halifax Port Corporation. ...

If, for example, the same vehicle was used in the yard to perform functions in connection with maintenance and several trials that were being conducted concurrently, then the cost of operating that vehicle, including the fuel used in it, would properly be considered overhead. ... Nor is it necessary to do so, as it appears from the appellant’s reply to the respondent’s written argument that the issue only arises in connection with trials #48, #49 and #50, which I have found do not qualify as SRED ...

., or any affiliate or subsidiary designated by it, whereby it will, because of its knowledge of the property, have the right to act as leasing agent, and when applicable, as sales agent for the limited partnership and to have any listing, whether for lease or sale, in connection therewith, in the event of leasing of available space or any sale of the Swansea Shopping Centre Project comprising the business of the limited partnership and shall be entitled to payment in the amount and on the terms usually paid to independent leasing or sales agents operating in the city of Toronto performing similar functions. 10.01 Each subscribing limited partner shall provide by way of initial capital contribution, for each unit acquired, the sum of $100,000, the sum of $12,500 which was delivered at the time of delivery of the subscription and the balance by cash or certified cheque on or before April 15, 1986. 10.02 Each subscribing limited partner shall further provide by way of capital contribution, for each unit acquired, the further sum of $100,000 such amount to be paid by way of delivery of a promissory note issued in favour of H.L. ... We request that our concerns are passed on as soon as possible to those responsible for the excavation and that Consumers’ Gas be notified so that they can inspect the connection. ...