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Results 1501 - 1510 of 6319 for connection
EC decision
Minister of National Revenue v. Roger Elkin Christie, [1964] CTC 165, 64 DTC 5099
Persons who are not actively engaged in the real estate business, but who have some connection therewith are eligible for associate membership. ... In May 1959 the respondent decided to sever his connection with Carruthers, Evans and Christie, Limited and to carry on business as a real estate broker under his own name and on his own account. ...
EC decision
Alexander Cole v. Minister of National Revenue, [1964] CTC 219
Arthur Minden’s connection with the so-called syndicate and details of the relationship of these members of it with each other during the years 1949 to 1956 are fully set out in the judgment of Cattanach, J. in M.N.R. v. ... (In this connection, it is relevant to note that there was no mention of partnership in that ease.) ...
EC decision
William C. Mainwaring v. Minister of National Revenue, [1964] CTC 341, 64 DTC 5214
Shortly afterwards, the appellant used his personal connections with Mr. ... Mainwaring, Esq., in connection with the Britalta Petroleums Ltd., of which the first three lines follow: ‘Dear Sir: I hand you herewith for your personal file a duplicate original of the agreement dated 5th May, 1949 between the above Company and the five promoters.” ...
EC decision
Leon Adler v. Minister of National Revenue, [1960] CTC 29, 60 DTC 1031
In connection with this taxation period, the respondent increased appellant’s assessable returns by adding $6,201.23 as net profit on the resale of a parcel of land in Ville St-Laurent, now the City of St-Laurent, one of the most thriving and progressive municipalities constituting the greater Montreal. ... In connection with the property that you acquired under Exhibit A4, did you need that much land for purposes of your own construction? ...
EC decision
Louis Norman Horowitz v. Minister of National Revenue, [1962] CTC 17, 62 DTC 1038
Section 59 provided for an appeal to the Income Tax Appeal Board to have the assessment to which objection had been taken vacated or varied and prescribed the time within which such appeal might be instituted, as follows: ‘ ‘59. (1) Where a taxpayer has served notice of objection to an assessment under section 58, he may appeal to the Income Tax Appeal Board constituted by Division I to have the assessment vacated or varied after either (a) the Minister has confirmed the assessment or re-assessed, or (b) 180 days have elapsed after service of the notice of objection and the Minister has not notified the taxpayer that he has vacated or confirmed the assessment or re-assessed; but no appeal under this section may be instituted after the expiration of 90 days from the day notice has been mailed to the taxpayer under section 58 that the Minister has confirmed the assessment or re-assessed. (2) Service of a notice of appeal under this section shall be served and all other matters in connection with an appeal under this section shall be regulated by Division I.” ... It read as follows: “60. (1) The Minister or the taxpayer may, within 120 days from the day on which the Registrar of the Income Tax Appeal Board mails the decision on an appeal under section 59 to the Minister and the taxpayer, appeal to the Exchequer Court of Canada. (2) Where a taxpayer has served a notice of objection to an assessment under section 58, he may, in place of appealing to the Income Tax Appeal Board under section 59, appeal to the Exchequer Court of Canada at a time when, under section 59, he could have appealed to the Income Tax Appeal Board. (3) All matters in connection with an appeal under this section shall be regulated by Division J.’’ ...
EC decision
Her Majesty the Queen v. Rexair of Canada Limited, [1956] CTC 108, 56 DTC 1056
Clause 7(a): “The parties hereto mutually agree that REXAIR shall hold RADIO harmless of any and all claims, actions, suits or proceedings for infringement or alleged infringement of any patent in carrying out this contract, and to indemnify RADIO against payment of royalties which may be payable in connection with any such patent; and for all damages, losses and expenses, including legal expenses which RADIO may or shall suffer or incur in connection with any such claim, action, suit or proceeding, provided that RADIO shall advise REXAIR of the pendency of any such claims or the institution of any such suit or other proceeding herein contemplated within ten (10) days, and permit REXAIR at its cost and in the name and behalf of RADIO and itself, to defend or adjust any such claim or claims.” ...
EC decision
Okalta Oils Limited v. Minister of National Revenue, [1955] CTC 39, 55 DTC 1029
During the Second World War it was found necessary to encourage and stimulate the production of oil in Canada; accordingly, by P.C. 3567 of May 4, 1943, authority was given under the War Measures Act for the incorporation of a Crown corporation—Wartime Oils Limited—charged with the duty of negotiating and entering into contracts for the carrying out of said objective and for the furnishing of financial assistance in connection therewith. ... As the companion well of Well No. 18 was productive, Wartime Oils might at some date acquire a 14 of 1 per cent royalty in perpetuity therein, but in the result it never could acquire any royalty in connection with Well No. 20 or its companion Well No. 22. ...
T Rev B decision
Rejean Garneau v. Minister of National Revenue, [1978] CTC 2440, [1978] DTC 1314
—where the taxpayer was employed in the year in connection with the selling of property or negotiating of contracts for his employer, and (i) under the contract. of employment was required to pay his own expenses, (ii) was ordinarily required to carry on the duties of his employment away from his 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 travelling expenses in respect of the taxation year that was, by virtue of subparagraph 6(1)(b)(v), not included in computing his income, amounts expended by him in the year for the purpose of earning the income from the employment (not exceeding the commissions or other Similar amounts fixed as aforesaid received by him in the year) to the extent that such amounts were not (v) outlays, losses or replacements of capital or payments on account of capital, except as described in paragraph (j), or (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 him: (h) Travelling expenses. ... There is no doubt that for 1973 and 1974 the appellant met the first condition provided for in paragraph 8(1)(f), that is, he was “employed... in connection with the selling of property or negotiating of contracts for his employer”. ...
T Rev B decision
Henri-Georges Lavoie v. Minister of National Revenue, [1978] CTC 2452
—all amounts received by him in the year as an allowance for personal or living expenses or as an allowance for any other purpose, except (i) travelling or personal or living expense allowances (A) expressly fixed in an Act of the Parliament of Canada, or (B) paid under the authority of the Treasury Board to a person who was appointed or whose services were engaged pursuant to the Inquiries Act, in respect of the discharge of his duties relating to such appointment or engagement, (ii) travelling and separation allowances received under service regulations aS a member of the Canadian Forces, (iii) representation or other special allowances received in respect of a period of absence from Canada as a person described in paragraph 250(1)(b), (c) or (d), (iv) representation or other special allowances received by an agentgeneral of a province in respect of a period while he was in Ottawa as the agent-general of the province, (v) reasonable. allowances for travelling expenses received by an employee from his employer in respect of a period when he was employed in connection with the selling of property or negotiating of contracts for his. employer, (vi) reasonable allowances received by a minister or clergyman in charge of or ministering to a diocese, parish or congregation for expenses for transportation incident to the discharge of the duties of his office or employment, (vii) allowances (not in excess of reasonable amounts) for travelling expenses received by an employee (other than an employee employed in connection with the selling of property or negotiating of contracts for his employer) from his employer if they were computed by reference to time actually spent by the employee travelling away from (A} the municipality where the employer’s establishment at which the employee ordinarily worked or to which he ordinarily made his reports was located, and (B) the metropolitan area, if there is one, where that establishment was located, in the performance of the duties of his office or employment, (viii) such part of the aggregate of allowances received by a volunteer fireman from a government, municipality or other public authority for expenses incurred by him in respect of, in the course of, or by virtue of the discharge of his duties as a volunteer fireman, as does not exceed $300, or (ix) allowances (not in excess of reasonable amounts) received by an employee from his employer in respect of any child of the employee living away from the employee’s domestic establishment in the place where the employee is required by reason of his employment to live and in full-time attendance at a school in which the language primarily used for instruction is the official language of Canada primarily used by the employee if (A) a school suitable for that child primarily using that language of instruction is not available in the place where the employee is so required to live, and (B) the school that the child attends is the school closest to that place in which that language is the language primarily used for instruction; 6. (6) Employment at special work site. ...
T Rev B decision
Robbie Holdings Limited v. Minister of National Revenue, [1978] CTC 3096, [1978] DTC 1819
In 1973 Mr Nemy commenced to act for a number of European investors in connection with the purchases by them of Manitoba farmland. ... Mr Nemy’s practice in connection with these purchases grew quickly and substantially. ...