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Results 1971 - 1980 of 6322 for connection
TCC

Miller v. The Queen, docket 97-1632-IT-G

The Minister disallowed the Corporation's claim for net expenditures in its 1993 and 1994 taxation years in the amounts of $39,347 and $51,034, respectively, in connection with its Firearms Division. ... Thus, if as a matter of fact a taxpayer is found not to have a reasonable expectation of profit, then there is no business and the taxpayer cannot claim any expenses in connection with that activity. [29]          When reviewing whether there is an expectation of profit and there is determined to be a personal element involved, Linden J.A. of the Federal Court of Appeal stated in Tonn v. ... No such analysis was given. [46]          The Corporation deducted investment tax credits in respect of qualified expenditures for SRED in connection with its 1993 and 1994 taxation years. ...
TCC

LBL Holdings Limited v. The Queen, 2018 TCC 63

This connection between Allind and LBL caused the CRA to believe that LBL may also have been selling tobacco products in non-compliance with the Act. ... It appears that LBL is simply asking for the contact information of anyone who had any connection with the case, no matter how remote, in the hope that it can find some beneficial piece of information. ... Subsection 95(4) of the Rules does not entitle taxpayers to the contact information of every person who had any connection with their file no matter how remote. ...
TCC

Gladwin Realty Corporation v. The Queen, 2019 TCC 62, aff'd 2020 FCA 142

The taxable portion of the capital gain must be reported by the limited partner like all other capital gains that may arise in connection with the disposition of a partnership interest. ... A capital loss can then be realized in connection with the disposition of a separate property. ... In paragraph m) of the PASF, the Appellant acknowledges that its representative had discussions with its Tax Advisor and legal counsel to determine the best timing to generate two capital gains and an offsetting capital loss for the purpose of generating two increases in the Appellant’s CDA in connection with the sale of the Property while paying no tax on the Second Capital Gain. ...
TCC

Robert Verrier & Fils Ltée v. Minister of National Revenue, [1992] 2 CTC 2464, 92 DTC 2354

When the transaction expands the income structure of the purchaser's business (Sunstrum, para. 4.02(6)). 4.03.5 Because in this appeal there were two transactions concluded by the appellant and there is no connection between the two, they should be examined separately. 4.03.6 Transaction with Michaud, Gagné & Vallée Inc. 4.03.6 (1) In this transaction, the concurrent existence of certain elements such as the significant goodwill purchased, the transfer of the $80,000 insurance portfolio and the expansion of the income structure were key elements which incline the Court toward the respondent's position. 4.03.6(2) In Muller & Co.'s Margarine Ltd., (para. 4.02(13)), Lord Lindley made the following comments on the property [sic] between the concept of "goodwill" and that of "a going concern”, at page 235: Goodwill regarded as property has no meaning except in connection with some trade, business, or calling. In that connection I understand the word to include whatever adds value to a business by reason of situation, name and reputation, connection, introduction to old customers, and agreed absence from competition, or any of these things, and there may be others which do not occur to me. ...
TCC

Michel Gravel v. Minister of National Revenue, [1992] 1 CTC 2521, 92 DTC 1935

This limitation on the evidence prevents a litigant from proving facts which have no real connection with the litigation or which has no probative force, and which at the same time might create confusion, drag out the argument, or cause unnecessary prejudice to his or her adversary (Ibid., page 343). Lack of relevance is generally argued either because a fact has no connection with the litigation or because it has no probative force (Ibid., page 344). For one fact to be relevant to another, there must be a connection or nexus between the two which makes it possible to infer the existence of one from the existence of the other. ...
TCC

Tom Jj. Zeiben v. Minister of National Revenue, [1991] 2 CTC 2008, 91 DTC 886

—He claimed an investment tax credit and a refundable investment tax credit in connection with the acquisition of the new equipment. ... He then reassessed the Appellant for the 1984 to 1987 taxation years in the following manner: —He reduced to nil the taxable capital gain in connection with the trade-in of the used equipment. —He decreased the investment tax credit and the refundable investment tax credit in 1984 and 1986 in connection with the acquisition of the new equipment. ...
BCSC decision

Robert G. Heath Et Al. v. Her Majesty the Queen, [1990] 2 CTC 28

The firm provided legal advice to the company in respect of the sale and in connection with it, received and disbursed funds for the benefit of the client in accordance with the client's instructions. ... All entries made in the records maintained by the firm in connection with the sale were made by an employee of it, not by either partner nor Mr. ... There is also a copy of a trust account record dealing with a client having no connection with the taxpayers. ...
TCC

Doris J. Neville v. Minister of National Revenue, [1988] 2 CTC 2201, 88 DTC 1546

.: —This is an appeal heard in Ottawa, Ontario, on June 24, 1988, against an income tax assessment for the year 1985, in which the Minister of National Revenue disallowed an amount of $525 claimed by the taxpayer as part of the expenses in connection with her income as a commission sales person. ... Thus, the expenses in connection with any course which gives a credit towards a degree, diploma, professional qualification or similar certificate may not be deducted. On the other hand reasonable expenses in connection with a course which, for example enables a professional to learn the latest methods of carrying on his profession are allowable. ...
TCC

Woodlin Developments Ltd. v. Minister of National Revenue, [1986] 1 CTC 2188, 86 DTC 1116

The second recital reads: AND WHEREAS the parties hereto desire to define and record by this Agreement as between themselves their respective interests and obligations in connection with their partnership in respect to the Mountview Subdivision. ... These facts, when taken in connection with the other facts of the case, may be of the greatest importance, but when there are other facts to be considered this section will not be of much assistance. ... Rather it provides for the inter-provincial connection of the parties’ individual telecommunications signals, with a complicated method of revenue settlement, whereby certain revenues received from the operation of the system are attributed to each. ...
TCC

Northcor Energy Ltd. v. R., [1998] 1 CTC 3178, 97 DTC 1060

Many of the underlying transactions commence with persons who, in 1984, had no connection at all with the Appellant and its affiliated or ancestor corporations. ... Maximum Amount of CEE To Be Incurred The Partnership agrees to incur CEE pursuant to this Agreement up to a maximum amount of the net proceeds which are raised by the Partnership pursuant to any offering of its limited partnership units in connection with this Agreement. 10. ... Lalji was disciplined by the Institute of Chartered Accountants for the Province of Alberta in connection with some of his professional services rendered to Exco. ...

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