Search - connection

The Board finds the connection between the surety given and the possibility of the appellant’s earning income too remote and not sufficiently direct. ... In the case at bar no evidence was adduced to show that there was a connection as direct as those in the aforementioned cases between the expenses incurred and the personal income of the appellant, who is a notary and not a shoe merchant. ... However, the Board must reject this possibility, since the connection between the surety and the possibility of the appellant’s earning income is too remote. 7. ...

On January 6, 1986, the collections section of Revenue Canada wrote to Giovanni Zen stating that, in connection with Pacific Refineries Inc., the corporation was indebted to the Department of National Revenue for payroll source deductions in the amount of $107,743.54 and that it was considering assessing him personally for that sum. ... It is noted in that connection that the defendant conceded in the agreed statement of facts that any information he requested of the plaintiff was provided, that he never asked for a determination of the amounts under each of the several statutes mentioned in the assessment and he did not ask for nor was he provided with copies of the corporate assessments or of the certificates filed in court. ... On March 23, 1988, a notice of assessment was sent to Giovanni Zen and Moreno Zen in connection with the 1985 taxation year assessment of Precious Metals. ...

., his wife and two children, moved to Lancashire, where they rented a furnished house, The Lodge, Thurland Castle, Tunstall, Lancashire; he maintained his family there until early May, 1945, when he then moved them to a furnished house in Scotland, namely Balgillo Crescent, Broughty Ferry, Angus, Scotland; he maintained his family there until mid-September, 1945, when he moved them back to the south of England to a rented house in Hertfordshire, namely Gorrans, 19 Cassiobury Park Avenue, Watford, Herts; they lived together in this house from the beginning of October, 1945, until they packed up to come to Canada in early May, 1946; the appellant, his wife and their children proceeded to Canada on the ‘‘Queen Mary”’ sailing from Southampton on May 4 and landing at Halifax on May 8, 1946, from where they proceeded by train to Ottawa, where they have since taken up permanent residence; during the taxation years 1941 to 1945, inclusive, the appel lant has paid income tax on his Canadian income under section 9(1) (d) and (h) of the Income War Tax Act; during the period 1940 to 1946, inclusive, the app ellant maintained a bank account and a safety deposit box in the Imperial Bank, Sparks Street, Ottawa, which were operated on his behalf in connection with his Canadian income and Canadian securities under power of attorney in favour of his father, T. Arthur Beament, K.C.; during the same period his personal civilian clothing was stored in Ottawa; during October, 1940, his motor car was sold in Canada to his account; during the period from February 22, 1941, to May 3, 1946, the appellant maintained his home for his wife and, subsequently, his children continuously in the United Kingdom, as hereinabove set out, and during the same period, except for his return to Canada for duty from September 23 to November 23, 1941, he was continuously in the United Kingdom or on the continent of Europe; during the same period he continuously operated his bank account in the United Kingdom in the Bank of Montreal, Waterloo Place, Pall Mall, London; In the statement of reasons to be advanced in support of the appeal the appellant alleges substantially: the assessment appealed from has disallowed the appellant’s claim to a deduction from tax in the sum of $657.00, under the provisions of section 7A(1) of the Income War Tax Act, although on the facts as above set forth he is entitled to the benefits of that section; in this connection the following reasons are advanced: (a) Taxability and consideration of section 9(1) of the Act. ... The proof reveals that during the period 1940-1946 the appellant maintained a bank account and a safety deposit box in a branch of one of the Chartered Banks in Ottawa and that they were operated for him in connection with his Canadian income under a power of attorney in favour of his father. ...

Then section 66 gave this Court exclusive jurisdiction to hear and determine " all questions that may arise in connection with the assessment”. ... All matters in connection with the appeal to the Board were to be regulated by the Third Schedule, which constituted the Board and regulated its procedure. ... All matters in connection with this appeal were to be regulated by the Fourth Schedule to the Act. ...

  [9]               This calculation suggested to him that almost all the reservations for stays of 30 days or more, which constitute an exempt supply, had no connection with the franchise agreement with Marriott, and that, as a result, the appellant was not required to pay the GST on the amounts remitted to Marriott ... Assessment under section 218 of the ETA     [17]          As stated above, the assessment of $30,720.51 made in this connection is now reduced to $27,290.23 to reflect the respondent’s concession of $3,430.28 with respect to the royalties paid by the appellant to Marriott for commissions paid to travel agents on short‑term rentals ... That case involved determining the percentage of the distance driven by a taxpayer in connection with his employment under subsection 6(2) of the Income Tax Act (ITA), and he decided that 85% could be considered "all or substantially all". ...

May I find that there is a rational connection between the means chosen and the objective of the classification? ... In enacting subsection 109(1)(b) Parliament required that there be a degree of connection between the dependant and a taxpayer for the taxpayer to be permitted the deduction. To sever the connection is a function of the legislature, not the Court. [25] In the two preceding cases the judges questioned whether it was appropriate for a court to decide the constitutional validity of a Provision of the Act in the context of an appeal of a tax assessment. ...

was not reimbursed for selling-related expenses incurred in the performance of his duties; (e)     the Appellant was married to Susan Bryson (the “spouse”); (f)      the Appellant was not required by his employer to hire an assistant; (g)     the Appellant did not pay his spouse to work as an assistant; (h)     the Appellant did not incur expenses of $18,000 for an assistant for the 2004 taxation year; (i)       the Appellant claimed meal and entertainment expenses of $1,774.83 and $5,669.50 in connection with the Lone Star Texas Grill restaurant and the Empire Grill restaurant respectively; (j)      the Appellant did not incur meal and entertainment expenses of $1,774.83 and $5,669.50 to earn employment income for the 2005 taxation year; (k)    the Appellant claimed $7,830.87 as lodging expenses for hotel accommodation at the Arc Hotel in Ottawa from March to June 2005; (l)       the Appellant did not incur $7,830.87 in hotel accommodation expenses for the 2005 taxation year to earn employment income; (m)   the Appellant was reimbursed by TD Waterhouse for the following expenses: Food, beverage and entertainment expenses  $6,527 Other Expenses    5,248 Travel    2,983 Total Expenses reimbursed by TD $14,758 (n)     the Appellant did not report the reimbursed amount of $14,758 as income in his income tax return ... 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. [13]   [42]          Parliament did not just reshape the requirement that the expenses claimed under section 62 be incurred in the course of moving, it removed the requirement entirely and replaced it with words of the widest scope of any expression intended to convey some connection between two related subject matters. ...

.: “As stated in Lindley on Partnership at p. 476, the expression ‘goodwill’, when applied to a business is generally used to denote the benefit arising from connection and reputation and its value is what can be got for the chance of being able to keep that connection and improve it.” ... It is the benefit and advantage of the good name, reputation, and connection to a business. ... It is the formation of that connection which has made the value of the thing that the late firm sold, and they really had nothing else to sell in the shape of goodwill.” ...

It is the whole advantage, whatever it may be, of the reputation and connection of the firm, which may have been built up by years of honest work or gained by lavish expenditure of money. ... James Brown and Sons Ltd.: “Goodwill” is a word sometimes used to indicate a ready formed connection of customers whose custom is of value because it is likely to continue. ... Muller & Co.’s Margarine Ltd. [1901] A.C. 217, 224, “the attractive force which brings in custom,” and it may reside, not only in trade connections, but in many other quarters, such as particular premises, long experience in some specialised sphere, or the good repute associated with a name or mark. ...

There are three other matters which might tend to indicate a tie or connection with Canada: 1. ... Commonwealth of Australia, [1951] AC 201, where Lord Simonds said at p. 219:... the substance of the obligation must be determined by the proper law of the contract, ie, the system of law by reference to which the contract was made or that with which the transaction had its closest and most real connexion. ... I am satisfied that, in all probability, this is the only connection which the plaintiff would have maintained with Canada had it not been for the above-mentioned legal requirements. ...