Search - connection

Filter by Type:

Results 1531 - 1540 of 6319 for connection
TCC

Yoon v. The Queen, 2005 DTC 1109, 2005 TCC 366

Also her social, cultural and religious connections in Koreawere much more extensive than those in Canada. ... The centre of vital interests test requires an examination of the taxpayer's connections to each country in that specific year. ... The court in Hertel (supra) did not place great weight on this intention despite the many connections the taxpayer had in Canada. ...
TCC

Arbeau v. The Queen, 2010 DTC 1203 [at at 3526], 2010 TCC 307 (Informal Procedure)

There were also some connections. Minor quantities of scrap metal were acquired from the salvage operations. ... There was no functional connection between the two activities- no interconnection, no interdependence, and no interlacing. ... The Appellant claimed that the cable connection was required to test TVs after they had been repaired. ...
TCC

Pioneer Designs Corp. v. MNR, 91 DTC 293, [1990] 2 CTC 2446 (TCC)

Also, the understanding was clear that whatever charges come from each of the directors in connection with the specific work of a project they are to be reasonable and competitive. ... This financial success can only be explained, on the facts of the present case, by the good work, connections and entrepreneurial skills of the five directors. ... In this connection, the approach adopted in the present case appears to me to be in line with the decision of Goetz, J. of this Court in the Earlscourt Sheet Metal Mechanical Ltd. v. ...
TCC

PDM Royalties Limited Partnership v. The Queen, 2013 TCC 270

Pizza Delight Corporation Ltd. and its subsidiaries (the “Company”) owned the trademarks, trade names, operating procedures and systems, other intellectual property and proprietary rights, and all goodwill used in connection with the restaurants and its franchisees (collectively, the “PDM Rights”). [5]              The Appellant was formed under the laws of the province of New Brunswick and its general partners are PDM Restaurants GP Incorporated (“PDM GP”) and the Company. ... The financing expenses were defined as certain fees and other expenses which were incurred in connection with the financing transactions. [12]         Mr. ... The Fund declared that it intended to qualify as a mutual fund trust and some of its activities, as listed in the prospectus, were: investing in securities, holding cash and short-term government debt, paying amounts payable by the Fund in connection with the redemption of any Units and making distributions to Unitholders, issuing Units for cash; issuing debt securities, purchasing securities, etc. ...
TCC

Morin v. The Queen, docket 95-650-IT-G

Charron (Exhibit I-1) in connection with the notarial contract of June 2, 1986. ... The following is a passage from his testimony in this connection: [TRANSLATION] 129. ... L'Ecuyer in connection with the transaction which is at issue in this Court. [21] The information obtained by Mr. ...
TCC

Hyswick v. M.N.R., docket 2002-721(EI)

Hyswick testified he paid his wife a salary of $1,000 per month to assist him in carrying on the home-inspection referral business as well as for performing research in connection with his duties for the City by checking for zoning infractions or lack of a proper building permit in respect of a particular property. ... He used his own cell phone in connection with both activities. He used his own vehicle for Housemaster business and, even though the City supplied him with a vehicle to be used in connection with his enforcement duties, there were instances when he chose to use his personal vehicle so as to be less obtrusive in the course of conducting an investigation. ... Certain forms had to be used and the opening of a file- in connection with an investigation- had to be logged into the City database. ...
TCC

Morris v. The Queen, docket 97-2-IT-G

The Appellant also made the following remarks in connection with the payment for his services: MR. ... In this connection, the following excerpt from the transcript is of some interest: MR. ... In this connection, he referred to the case E. Winemaker v. Canada, [1995] 2 C.T.C. 2992 and 96 DTC 6040. ...
FCTD

Corp. Steckmar/Steckmar Corp., Re, 2004 FC 581

The Queen, supra, at page 233, seem appropriate in this case: If the Court thus had to withdraw immediately a question of provincial law [that] came before it in connection with the disposition of an action in the Court, not many actions could be taken to their conclusion. ... Frato Construction inc., [1984] S.C. 573, at 575, in connection with an objection by the defendant to the seizure by the plaintiff of a right of action exercised by the defendant, the Superior Court wrote: [TRANSLATION] If the debt against Pisapia Inc. in case 500-05-003853-783 is in fact owed to Frato Construction Inc., the plaintiff's debtor, garnishment would be required, not the seizure in execution proceeding. ... Only its time of payment remained to be decided following the statement by the garnishee. [41]      On this question of the payment date I think that Rule 453, which provides that the Court may determine any question of a garnishee's liability, enables the Court to consider the possible application of article 1512 C.C.Q. in connection with a garnishment. [42]      Further, relying on Income Tax Act et al. v. ...
FCTD

Nelson v. The Queen, 2001 FCT 1132

The harassment of the Crown, by attempting to subpoena witnesses who do not only have no connection to the cause of action but also who appear not to be required to prove or produce documents or to answer relevant questions, is scandalous and even outrageous conduct, particularly where at least one of the subpoenas has been specifically denied in the past. ... Prothonotary Hargrave further ordered the Plaintiff was not permitted to file any further documents with this Court, except as to any appeal of this Order and in connection with any outstanding appeals, until the costs of this motion had been paid. 25.        ... Prothonotary Hargrave, further ordered the Plaintiff was not permitted to file any further documents with this Court, except as to any appeal of this Order and in connection with any outstanding appeals, until the costs of this motion had been paid. 26.        ...
SCC

Montreal Coke and Manufacturing Co. v. Minister of National Revenue / Montreal Light, Heat & Power Consolidated v. The Minister of National Revenue, [1942] SCR 89

In connection with the operation, the appellant company incurred certain disbursements and expenses amounting to $2,282,679.42 and proposed to amortize the same over the life of the new bonds, the amortized amount sought to be deducted in 1936 amounting to $104,596.04. ... The operation in connection with which these disbursements were made was simply this: Capital was borrowed at an agreed rate of interest for the purpose of repaying to the creditors the existing debt in respect of borrowed capital for which the company was paying a more onerous rate of interest. ... The learned President further stated that the law in England is different and English decisions could have no application here * * * In the United States, expenses incurred in connection with the refunding or retirement of bond issues are governed by a set of rules issued by the Treasury Department in 1938, and it is probable that there, under such rules, the disbursements here would be allowed as deductions. ...

Pages