Search - connection
Results 1961 - 1970 of 6319 for connection
TCC
St-Isidore Écono Centre Inc. v. The Queen, 2008 TCC 280 (Informal Procedure)
(g) While auditing the Appellant's books, the Minister's auditor noticed that, in computing its net tax, the Appellant, starting in 2001, had been claiming undocumented ITCs in connection with supplies purportedly received from Ferblanterie Alexandre and D.H. ... (m) As for the invoices submitted in connection with the ITCs claimed on supplies purportedly received from D.H. ... (ff) During the audit, the Minister's auditor therefore disallowed ITCs claimed by the Appellant in connection with the invoices purportedly issued by St-Isidore. ...
TCC
Axa Canada Inc. v. The Queen, 2006 TCC 334, 2006 TCC 4
He presented an analysis of the losses suffered by Abeille Ré in connection with the two bailout agreements described above. ... Lessard was asked to prepare a report dated June 30, 1993, on the situation with respect to reserves in connection with the agreement of September 30, 1990. ... In late 1992, it was believed in Paris that the losses in connection with this investment exceeded $100 million. ...
TCC
Monias v. The Queen, docket 96-334-IT-I (Informal Procedure)
With respect to the last guideline, Revenue Canada observed that:... in the case of non-commercial activities of a band or tribal council representing Indians on a reserve or an organization controlled by one or more of these entities and dedicated to the social, political, economic or cultural development of those Indians which is resident on a reserve, it is reasonable to conclude that there is sufficient connection to a reserve to warrant an exemption. ... Emphasis added With respect to each of the foregoing examples, it was the position of Revenue Canada that sufficient connection would exist to a reserve to locate the income there and grant the tax exemption. [8] [22] On March 7, 1994, the Assistant Deputy Minister, Legislative & Intergovernmental Affairs Branch, Revenue Canada, wrote to the Awasis agency confirming that its employees were not exempt from income tax on their employment income because: As you know, draft guideline # 4 requires an organization to meet various criteria in order for its employees to be tax exempt. ... In these circumstances, giving much weight to the situs of the employer as a connecting factor would be less than satisfactory in achieving the legislative purpose behind the section 87 tax exemption. [29] I turn next to the connection between Awasis and the reserves it serves as well as the manner in which that employment benefited the reserves. ...
TCC
Lallier v. The Queen, docket 1999-3925-IT-I (Informal Procedure)
In connection with that research, he had to hire an assistant at a cost of $400. ... Lallier included money received in connection with various activities, such as teaching. ... In respect of the work as a lecturer, he claimed to be self-employed and to be entitled to deduct expenses of $709 in connection therewith. ...
FCTD
Canada (National Revenue) v. Park, 2011 FC 263
Offshore Connection [45] The Park family is known to have connections to Asia. ... [46] Hugo had connections to Puerto Rico and now resides in the USA. ... That date is unlikely to be any time soon; d) Sung has been conducting her affairs in an unorthodox manner; e) Sung’s Assessment itself is unorthodox as are the assessments concerning Hugo, 214 Holdings and 835667, some of which were the subject of jeopardy orders; f) The Park Family has offshore connections and is known to move significant funds offshore presumably for Doo’s benefit; g) Hugo and Sung appear to be used by Doo as nominees. ...
FCTD
Gordon v. Canada, 2007 FC 253
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. ... The Pocket Oxford Dictionary (1984) defines the word "relation" as follows: ... what one person or thing has to do with another, way in which one stands or is related to another, kind of connection or correspondence or contrast or feeling that prevails between persons or things;... ...
SCC
Firestone Tire and Rubber Company of Canada, Ltd. v. Commissioner of Income Tax, [1942] SCR 476
The appellant company, on April 8th, 1938, was assessed in respect of income in connection with sales of its products in British Columbia by M., W. ... The distributor may, subject to the terms, provisos, conditions and agreement resell in the usual and ordinary course of his business, but not otherwise, any of the Firestone products delivered or to be delivered by the Company provided, however, that no article shall be sold by the distributor at a price less than the list price established from time to time by the Company *** less such discounts as may be authorized from time to time in connection with the prices so fixed or to be fixed by the Company. ... In this connection there remains but to add that the carrying out of the agreement strengthens the above conclusion, particularly the fact that in the general financial balance of the Company the goods warehoused with the distributor are included on the asset side under the heading of " inventories ". ...
FCA
Canada v. Monias, 2001 FCA 239
The factors connecting the income to the reserve are not as strong: in particular, the employees do not reside on the reserve and two have no connection at all with a reserve. ... However, the fact that Awasis does not conduct its business on a reserve and hence, apparently, provides no employment opportunities on reserves, points to an off-reserve residency and hence weakens the connection between the employer and the reserves for the purpose of determining the situs of the respondent's employment income under paragraph 87(1)(b). [56] I would note, again, the contrast with Amos, supra, where the employer did conduct its business on reserve land, which had been leased to it for this purpose on the understanding that employment opportunities in the business would thereby be created for members of the Band. ... Where employees receive their employment income has little, if any, logical connection with the policy underlying section 87. [58] Since the policy underlying section 87 is to protect the reserves as an economic unit for the members of the Bands living there, the residency of employees can be a significant factor in determining the situs of employment income. ...
FCA
Canada v. Calgary (City), 2010 FCA 127
While the agreements covered both roadway construction and public transit facilities, we are only concerned with the latter since no issue of exempt supply arises in connection with roadway construction ... [7] Prior to 2003, the City claimed public service body rebates under section 259 of the Act with respect to GST paid in connection with the development of its transit system. ... This resulted approximately 56% of the GST paid by the City being returned to it in the form of rebates. [8] However, in January 2003, the City filed a GST return for the period ending December 31, 2002, in which it claimed input tax credits with respect to GST paid in connection with the development of its transit system up to that time. ...
TCC
Woessner v. The Queen, 2017 TCC 124
Factor 8 – The Relationship/Connection between Counsel, the Prospective Witness and the Parties Involved in the Litigation: [49] There are two connections at play that raise concern. ... Mamdani is a former associate with the firm, his precise present connection with Appellant counsel is unknown as there appears to be a continuation of strong links between this individual and Appellant counsel’s law firm. ... When counsel of record has the type of intricate “connection” to a witness, as in this case, there can be no assurances to the court, the public or the client that counsel, in fact and in appearance, will act objectively in those duties. ...