Search - connection

The judge, accepting that Mr Smith fell well short of the required period of residence (by 665 days), concluded that he had established himself in Canada and had maintained that connection even during his lengthy absences to work in the US. ... The judge found that Mr Smith held real property in Canada, as well as an automobile, that he had bank accounts here, that he paid taxes in Canada, and that he had social connections and other ties to Canada. ... The focus in these cases is on what the person did on arrival to Canada, what connections were made here, how strong those connections were, how long he or she stayed in Canada before leaving, what the purpose of the absences from Canada was, and how extensive were the absences. [11]   A person who has a firm connection with Canada can be regarded as a resident even though he or she is often outside the Canada for legitimate reasons. ...

When a householder desires the service offered by one of the appellants a cable connection must be effected between that householder’s television set and the distribution cable. The cost of supplying and installing that portion of the cable connection which is within the subscriber’s house has been treated by the respondent as a current cost. ... There is no connection between the appellants’ motives in fixing the amounts charged to their customers for hook-up and the nature of the expenditure made in order to effect the hookup. ...

This paragraph contains two provisions, the first one relating to “use by Her Majesty or by Her agents or servants in connection with the manufacture or production of goods...”. ... The alternative interpretation would establish a conjunction between use in connection with the manufacture and production of goods and use for other commercial or mercantile purposes. ... The duty of the court is... to give effect to the intention of the Legislature as that intention is to be gathered from the language employed having regard to the context in connection with which it is employed. ...

Given that a Crown witness admitted that the Minister allows for ITCs for certain items such as work gloves and boots acquired by other farm registrants for use by their employees, I am of the opinion that the connection for the [Work Cloth] … is not too remote ...      [11]         In a strong dissent, Evans, JA rejected the majority’s conclusion but accepted its analysis that “… for the goods to be acquired for use ‘in the course of commercial activities’, there must be a functional connection between the needs of the business and the goods.” [4] On his view of the facts, no such connection existed:   68        No doubt it will not always be easy to draw the line between an ITC-eligible good consumed in the process of the commercial activity … and … one that is not because it satisfies a personal need of the registrant and has only a tenuous connection with the registrant’s commercial activities.   69        Whether a good was acquired for use “in the course of commercial activities” may often require an assessment of the whole factual context, and a weighing of the various factors indicative of the good’s functional integration into the commercial activity. ... Expressed in terms of Midland Hutterian Brethren, there is a “functional connection” between the supply and the performance of employment duties; under ExxonMobil, that connection would preclude a finding that the meals were for the “exclusive” personal use of the employees ...

Martin was reassessed to disallow his claim to be entitled, in computing his income under section 3 of the Income Tax Act (the Act), to deduct the losses which he claimed to have sustained in each of those years in connection with a rental property owned by him and his wife in Florida, and in connection with a business which involved the buying and selling of sports cards. ... Martin was reassessed to disallow her claims to losses in connection with the Florida property, and to disallow claims in each of the three years for losses incurred in connection with the rental by her to her husband of space in the basement of the family home, for use in connection with the sports card business. ... Martin, for her part, takes the position that she is entitled to deduct losses incurred by her in connection with the rental of the basement space to her husband. ...

Counsel concluded from these two cases that there must be a clear connection between the payment and the contract of employment for the definition of retiring allowance to apply. ... This Assignment includes full power of substitution of the Province for me in connection with my claim. ... They import such meanings as "in relation to", "with reference to" or "in connection with". ...

Martin was reassessed to disallow her claims to losses in connection with the Florida property, and to disallow claims in each of the three years for losses incurred in connection with the rental by her to her husband of space in the basement of the family home, for use in connection with the sports card business. ... All did not go well in connection with the rentals, however. They had difficulty getting people to rent the property. ... The largest single expense in connection with the property is for interest on the money borrowed to purchase the units. ...

The connection put forward by BlackBerry Canada does not fit into the type of nexus to which paragraph 95(3)(b) refers. ... “In connection with the sale of goods”: paragraph (b) [77] The Respondent argued that the services performed in connection with the sale of BlackBerry handheld devices do not fit into the type of connection to which s.95(3)(b) refers. [78] BlackBerry Canada’s argument that “in connection with” should be interpreted broadly relies on a Supreme Court of Canada decision which ascribes to the phrase equivalency to the meaning given to the phrase “in respect of”. ... In the alternative, such services were paid in connection with the sale of goods or the manufacturing or processing of tangible property outside Canada. ...

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. Here, in my view, the use of those words within the definition of "retiring allowance" as found in subsection 248(1) of the Act surely conveys a connection between the plaintiff’s loss of employment and his subsequent receipt of the amount of $60,000 as paid by his former employer, AECL. ...

ON APPEAL FROM THE EXCHEQUER COURT OF CANADA Income tax—Deductions in computing income—Legal expenses incurred in defending suit against using certain words in connection with sale of products—Income War Tax Act, R.S.C. 1921, c. 97, s. 6 (a) (b). ... In the present case it was held that legal fees and expenses incurred by respondent in successfully defending a suit for an injunction against alleged infringement of registered trade marks by using certain words in connection with the sale of respondent's products, fell within that general rule; in that suit the question in issue was whether or not said trade marks were valid, and the right upon which respondent relied was not a right of property, or an exclusive right of any description, but the right (in common with all other members of the public) to describe its goods in the manner in which it was describing them. ... APPEAL by the Minister of National Revenue from the judgment of Maclean J., late President of the Exchequer Court of Canada [1], allowing the appeal of The Kellogg Company of Canada, Limited, the present respondent, from the decision of the Minister of National Revenue affirming certain assessments against said company for income tax under the Income War Tax Act, R.S.C. 1927, c. 97, which assessments disallowed as deductions, in computing the company's income, the amounts of legal fees and expenses incurred in defending a suit brought against it in which there was claimed an injunction to restrain an alleged infringement of registered trade marks by the present respondent's use of certain words in connection with the sale of some of its products. ...