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Results 1841 - 1850 of 6321 for connection
TCC
Promutuel Réassurance v. The Queen, 2020 TCC 13
On September 21, 2010, the appellant provided the Canada Revenue Agency with additional information in connection with its request for an advance ruling dated June 29, 2010. 41. On December 1, 2010, the appellant provided the Canada Revenue Agency with additional information in connection with its request for an advance ruling dated June 29, 2010. 42. ... The common connection might include, inter alia, a voting agreement, an agreement to act in concert, or business or family relationships. 58. ...
EC decision
The International Nickel Company of Canada, Limited v. Minister of National Revenue, [1969] CTC 106, 69 DTC 5092
That searching is a prevailing aspect of a mining company’s business at all stages and that Parliament meant that all expenses incurred in that connection should be deductible. 16. ... A reference to “development” in connection with a mine extends to various operations which must be undertaken in preparation for the removal of ore from the mine. ... His conclusion in respect to the subject matter, he stated in these terms: I have been informed with regard to the part played by Inco in building and developing the townsite of Thompson, Manitoba, and the costs incurred by it in that connection. ...
TCC
Global Communications Ltd. v. R., [1997] 3 C.T.C. 2499, 97 D.T.C. 1293
The body of that letter reads: Re: Petroseis Data Sale In connection with the referenced matter and further to our telephone conversation of today's date I enclose herewith our firm trust cheque in the amount of $2,140,000.00. ... Such receiver shall have the right to liquidate the Purchaser's interest in the Assets by sale to any bona fide third party purchaser, unrelated to the Vendor or a person related to the Vendor under the provisions of the Income Tax Act (Canada), and shall apply the proceeds of such liquidation, after payment of all costs incurred in connection with such liquidation, to the outstanding indebtedness under the Promissory Note to the extent of the balance thereof. ... Indeed, it is conceded that, if the seismic work here had been done in connection with a drilling program, its costs would be an eligible exploration expense. ...
EC decision
Killarney Properties Limited v. 304 ; Minister of National Revenue, [1965] CTC 101, 65 DTC 5060
Future plans of the company in connection with the shopping centre revolved around selling the property. ... The meeting concluded with the following declaration of intent: “Future plans of the Company in connection with the shopping centre revolved around selling the property. ... In this connection there was some equivocation in the evidence of Mr. ...
EC decision
Minister of National Revenue v. James Karfilis, [1966] CTC 498, 66 DTC 5327
Karfilis paid to Walters in connection with his obligations under the Wheeler agreement, the sum of $3,760. 7. Karfilis paid various miscellaneous expenses in connection with all the claims, the sum of $313.94. 8. ... Now, in connection with your arrangement with Mr. Byles he was a completely—to use a little legal word and since you are a law student, we can agree that he was an independent contractor, can we? ...
BCPC decision
Qix Facilities Corp, Canada V., [1992] 2 CTC 383
Bradley Sakich, a chartered accountant with Coopers & Lybrand in 1985, explained his work with Schmidt and Zink, and that his involvement was principally with Zink in connection with the release of funds held in escrow by The Canada Trust Company. ... Grant Cowan, with Revenue Canada, and the principal investigator in this case produced documents filed by QIX in connection with the sale of its scientific research tax credit note to Consumers’ Gas. ... In connection with expenses claimed by QIX in its Part VIII and Part I returns, Cowan examined statements filed with the returns, accounting documents and then the source documents such as cancelled cheques and working papers. ...
MBCA decision
In Re the Winnipeg Charter, City of Winnipeg v. T. Eaton Company Limited, [1944] CTC 128
The said building was and is used in part in connection with its Departmental Store business and in part in connection with its Mail Order business. ... In this warehouse the Company at all material times warehoused goods to be used partly in connection with its Departmental Store business and partly in connection with its Mail Order business and also maintained therein a printing plant, chiefly used for the purpose of printing catalogues for its Mail Order business, and also maintained a creamery, the products of which were sold by the Company in its retail business. ^6. The Company appealed from the five assessments referred to in paragraph 5 hereof: to this Board for the following reasons as stated in each of the notices of appeal, namely: " 6 ‘Such assessment is based on too high an annual rental value. ‘ " ‘ and the said appeals are now pending and this case is stated in connection with the said appeals. ...
FCTD
Roy v. R., 2002 FCT 233
The first question at this stage is whether there is a rational connection between the goal of the legislation and the means chosen by government to implement its objective. ... It is, therefore, rational that a program designed to benefit couples in such circumstances would be focused on cohabiting spouses. [84] The plaintiffs submit that there cannot be a rational connection between the aims of this legislation and these provisions, and that if there was a rational connection then separated spouses would also be excluded. ... In my view, there is a rational connection between the means and the objectives of this legislation. [85] I will now turn to the minimal impairment stage. ...
TCC
Allegro Wireless Canada Inc. v. The Queen, 2021 TCC 27
In particular, the objective was to develop methods to enable more efficient streaming of digital audio, connection-handling mechanisms to translate UDP to TCP and reduce the overhead related to TCP timeouts. [3] [144] Mr. ... Because of the latency of cellular networks, it is not easy to determine whether a connection has timed out. [186] Mr. ... Doctor Penn’s Opinion [191] Doctor Penn explained that in order for the Appellant to keep the connections from timing out, it needed to consider the limited CPU capacities and networking capacities of each of the devices involved. ...
EC decision
Minister of National Revenue v. Kenneth A. Wheeler, [1966] CTC 526, 66 DTC 5341
In this connection, the following portion of his evidence is of interest: “Q. ... I propose to deal first with the evidence in connection with prospecting. ... Whalen had disposed of his interest in the Dismal Lake claims other than in connection with the Vandoo sale? ...