Search - connection
Results 1431 - 1440 of 6323 for connection
FCTD
Singh v. Canada (Citizenship and Immigration), 2019 FC 969
According to the Applicant, the Officer failed to consider his connections to India, specifically his family ties and property. [12] The Applicant also says the lack of travel history can only be a neutral factor in assessing an application for temporary residence, and the Officer erred by considering his travel history as a negative factor. ... However, reasons that are abstract, vague or not founded on objective evidence may constitute a factor, among others, that will lead the officer to conclude that the foreign national has not met the burden of demonstrating that he or she will leave Canada at the end of the authorized period of stay [citations omitted]. [17] In view of the Applicant’s vague reasons for the visit, it was reasonable for the Officer to conclude that he had not met the burden of demonstrating that he would leave Canada at the end of the authorized period of stay. [18] The Applicant’s complaint that the Officer failed to consider his connections to India is without merit. ...
FCTD
Muliisa v. Canada (Citizenship and Immigration), 2019 FC 1490
She submits that her ex-spouse, the agent of her persecution, has connections at the highest levels in Uganda and it is reasonable to expect that he will use his connections to find her and harm her in Rwanda. ...
FCA
632738 Alberta Ltd. v. Canada, 2021 FCA 43
They are: (i) in light of subsection 152(4.01) of the Act, the scope of the waiver includes transactions that are related or connected to the transaction specified in the waiver; (ii) the record before the Court does not clearly demonstrate that the scope of the waiver is limited to allocations of income from Thompson GP; (iii) a stage 2 hearing would unfairly preclude the Crown from conducting examinations for discovery of the individual who signed the waiver; (iv) the onus is on the Crown to prove a reasonable connection between the reassessment and the matter specified in the waiver; and (v) the Court tasked with determining the scope of the waiver will require a full understanding of the factual circumstances that led to the reassessment, and for this purpose it is necessary for the Court to have evidence substantially similar to the evidence relevant to the merits of the case. [21] At the outset, I would observe that many of the Tax Court’s findings, above, decide issues that ultimately will have to be decided by the judge tasked with determining the scope of the waiver. ... The Tax Court did not err in rejecting 632’s submission. [31] Fourth, the Tax Court determined that the Crown will have the onus of proving a reasonable connection between the reassessment and the matter specified in the waiver. ...
TCC
6398316 Canada Inc. v. The Queen, 2021 TCC 17
These claimed expenditures were incurred in connection with a construction project carried on by the Appellant during those two years. ... They would have been expected to “power the home”. [7] [21] The connection between roof trusses and tops of walls was the focus of air sealing utilizing a peel and stick membrane to ensure air tightness. [8] This is more air sealing than in a code built home, but is important because much heat loss typically occurs through the attic. ...
TCC
Paul Aucoin v. Minister of National Revenue, [1991] 1 CTC 2191, 91 DTC 313
In this connection, it was mentioned in a letter dated January 14, 1988 to the Department of National Revenue by the appellant's accountant in support of the contention that the above property was purchased with the intention to earn income that" it was expected that the income would increase at the rate off] inflation and the mortgage payment would remain constant producing a substantially larger income". ... Having regard to the observations made in the preceding cases, it would be unreasonable, in my view, to conclude that the appellant ceased overnight to have a reasonable expectation of profit in connection with the rental of the subject property as soon as the slump in the real estate market surfaced. ...
TCC
Transport Jacques Lemieux Inc. v. Minister of National Revenue, [1991] 1 CTC 2612, 91 DTC 503
The purchase of the tanker truck seemed justified at the time by the fact that another lower powered tanker truck had become inadequate to meet the appellant's requirements in connection with its ability to perform its obligation to Agrinove under annual transportation contracts between the appellant and that business. ... However, the factor of time was emphasized by counsel for the appellant and I feel that it is also relevant here, since there were several activities in connection with use of the truck, namely collecting the milk, its transportation and delivery and finally returning empty for another load on the same day, and so on the following day. ...
TCC
Wright v. R., [1996] 1 CTC 2029 (Informal Procedure)
Although the appellant and her spouse borrowed $30,000 from the Bank of Nova Scotia, I find that these funds were used not in connection with the purchase of 74 Alderbury as alleged by the Minister, but were used to reduce the mortgage on their matrimonial home since the rate charged for the loan was less than the mortgage rate on the home. ... In allowing the appeal from the Minister’s reassessment, Garon J. made the following comments at page 2193 (D.T.C. 316): it would be unreasonable, in my view, to conclude that the appellant ceased overnight to have a reasonable expectation of profit in connection with the rental of the subject property as soon as the slump in the real estate market surfaced. ...
TCC
Bouchard v. Minister of National Revenue, [1996] 1 CTC 2239
It is in connection with this $6,500 contribution that the appellant claimed a deduction of this same amount in calculating his income for the year 1987. ... In connection with this subject see the decision of the Federal Court of Appeal in Uppal v. ...
ABCA decision
Satellite Earth Station Technology, Inc. And David B. Brough v. Her Majesty the Queen, [1995] 2 CTC 445
Therefore, there is no evidence of any connection between the wage withholdings and this inventory. Indeed, it is very probable that at least part of the Minister’s claim cannot have any connection whatever to this inventory. 2. ...
TCC
David Krull v. Her Majesty the Queen (Informal Procedure), [1995] 2 CTC 2204, 95 DTC 206
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. ...