Search - connection
Results 1991 - 2000 of 6321 for connection
TCC
Grenon v. The Queen, 2021 TCC 30
Reports were filed in connection with the First Distribution but no evidence was adduced to demonstrate that reports were filed in connection with the Second Distributions. d) The income distributions made by the Income Funds [48] The profits from the various investments or businesses were flowed-up through the various entities, including the FVT’s, to the Income Funds and were then distributed to unitholders, including the RRSP Trust. ... She acknowledged that a T3 return had not been filed with the CRA in connection with the RRSP Trust. ... However, I must conclude that she did so only in connection with the taxable plans and not in connection with the non-taxable plans that were listed for information purposes only, including the RRSP Trust. [534] As noted above, subsection 152(3) provides that “liability for tax” is not affected “by the fact that no assessment has been made.” ...
SCC
Premium Iron Ores Ltd. v. Minister of National Revenue, 66 DTC 5280, [1966] CTC 391, [1966] S.C.R. 685
It paid out for legal costs in connection with that action the sum of $10,377 in 1938 and $22,952.80 in 1939 and included these disbursements as deductible expenses in its income tax returns for the said years. ... Sums paid by a company to settle an action for fraud in connexion with its trade have also been allowed, together with incidental legal expenses (k) {Golder (Inspector of Taxes) v. ... Proceedings there had been brought against the com pany to restrain it from using certain ordinary descriptive words in connection with the sale of its products and the expenses had been incurred in successfully resisting them. ...
TCC
Birchcliff Energy Ltd. v. The Queen, 2017 TCC 234
Birchcliff approached several financial institutions including Scotia Capital in connection with financing the acquisition of the Devon Properties. 23. ... On April 18, 2005, Birchcliff notified the TSXV in connection with the proposed transactions. [45] 39. On April 18, 2005, Veracel notified shareholders of a special meeting in connection with proposed transactions. [46] 40. ...
SCC
MacDonald v. Canada, 2020 SCC 6, [2020] 1 SCR 319
Turning to the question of linkage, while the timing connection and quantum connections are imperfect, during its existence the forward contract achieved a theoretical partial economic hedge of M’s ownership risk in the Bank of Nova Scotia shares. ... MacDonald did not sell his Bank of Nova Scotia shares immediately to offset his losses under the forward contract does not sever this connection. ... The timing connection between the Forward Contract and the BNS Shares is weak, because Mr. ...
TCC
Martin v. The King, 2024 TCC 153
As to the two Basic Rules under Part I ITA, they apply with close interaction and connection, and guide the taxpayer to calculate income by clustering sources of income together on a source-by-source basis. ... This is consistent with Canadian and international tax principles providing that there needs to be a sufficient connection with a state for that state to levy tax. ... Contributions to the RCA fund are to be made (i) by the employer of the taxpayer and (ii) in connection with benefits that are to be or may be received or enjoyed by any person on, after or in contemplation of any substantial change in the services rendered by, the retirement of or the loss of employment of the taxpayer. ...
FCA
Canada v. Yudelson, 2010 DTC 5040 [at at 6674], 2010 FCA 44
This prescribed amount is determined by the formula A x B, where A is the amount of the individual’s LRBs commuted in connection with the transfer, as determined by subsection 8517(4), and B is a present value factor listed in the Regulations and corresponding to the individual’s age at the time of the transfer. [10] Essentially, LRBs are retirement benefits provided to the member until the member’s death (subsection 8500(1) of the Regulations) that must be “payable in equal periodic amounts” (paragraph 8503(2)(a)). [11] Subparagraph 8503(2)(a)(ii) provides an exception to take indexation increases into consideration: LRBs do not need to be paid in equal periodic amounts where a plan “provides for periodic cost-of-living adjustments to be made to the benefits”. ... Therefore, the value of “A” in calculating the prescribed amount, that is the amount of individual’s LRBs commuted in connection with the transfer, is equal to 0, and the prescribed amount (A x B) is also equal to zero. [40] This interpretation is consistent with the overall scheme of the Act. ... Amount of Lifetime Retirement Benefits Commuted (4) For the purposes of subsection (1), and subject to subsection (7), the amount of an individual’s lifetime retirement benefits under a defined benefit provision of a registered pension plan commuted in connection with the transfer of an amount on behalf of the individual in full or partial satisfaction of the individual’s entitlement to benefits under the provision is the aggregate of (a) where retirement benefits have commenced to be paid under the provision to the individual, the amount (expressed on an annualized basis) by which the individual’s lifetime retirement benefits under the provision are reduced as a result of the transfer, (b) where retirement benefits have not commenced to be paid under the provision to the individual, the amount (expressed on an annualized basis) by which the individual’s normalized pension (computed in accordance with subsection (5)) under the provision at the time of the transfer is reduced as a result of the transfer, and (c) where, in conjunction with the transfer, any other payment (other than an amount that is transferred in accordance with subsection 147.3(5) of the Act or that is transferred after 1991 in accordance with subsection 147.3(3) of the Act) is made from the plan in partial satisfaction of the individual’s entitlement to benefits under the provision, the amount (expressed on an annualized basis) by which (i) if paragraph (a) is applicable, the individual’s lifetime retirement benefits under the provision are reduced, and (ii) if paragraph (b) is applicable, the individual’s normalized pension (computed in accordance with subsection (5)) under the provision at the time of the payment is reduced, as a result of the payment, except to the extent that such reduction is included in determining, for the purposes of subsection (1), the amount of the individual’s lifetime retirement benefits under the provision commuted in connection with the transfer of another amount on behalf of the individual. ...
TCC
Canada Trustco Mortgage Co. v. MNR, 91 DTC 1312, [1991] 2 CTC 2728 (TCC)
Mortgage regarding amounts overdue; (f) maintaining fire and other insurance (where applicable) to protect the interest of the Purchaser in the property securing the Mortgage; (g) providing any necessary services in connection with the settlement of loss in the event of age to or destruction of the property securing the Mortgage by fire or other insured hazards and in the disposition of insurance proceeds; (h) taking of such steps as may be necessary for the exercise of any remedy available to the Purchaser in the event of default occurring under the Mortgage; (i) maintaining in good standing the mortgage loan insurance policy with respect to the Mortgage; (j) subject to the provisions of paragraph 5, providing any necessary services in connection with instituting and conducting a judicial sale or foreclosure action with respect to default and making claim for payment under the mortgage loan insurance policy on behalf of the Purchaser and payment of the proceeds of such policy to the Purchaser after making all deductions therefrom authorized pursuant to this Agreement. 4. ... The Administrator shall not be required to advance funds for any purpose in connection with any of the Mortgages, and in particular shall not be required to pay premiums of insurance, taxes, charges for public utility services in arrears, fees payable to any Land Titles Office or Land Registry Office or costs of repairs or maintenance of the property securing a Mortgage, but shall be at liberty to do so if the Administrator deems it advisable, provided that the Administrator shall forthwith notify the Purchaser if funds are required in connection with the administration of, or the protection of the security when the Administrator chooses not to advance its own funds for such purposes. ... No further intervention or supervision was done on its behalf nor were any directions given in connection with its day-to-day operations. ...
TCC
Shaw Communications v. M.N.R., docket 2000-1446-EI
All of the witnesses described their connection with Shaw during the period in question. ... Morris and Fenwick) or persons who had a prior connection with Shaw during the period in question (like Messrs. ... The Respondent's four witnesses had a connection with Shaw during the period in question but that connection was terminated and they had no connection with Shaw or Rogers at the time of hearing. [6] Richard Morris, Shaw's vice-president of operations, has been a continuous employee of Shaw or its predecessor since 1978. ...
TCC
Huang v. M.N.R., 2009 TCC 35
The internet connection was at their residence and she did some work for the Clinic from there. ... She denied having informed the Rulings Officer that she was performing services for her husband in December in connection with any business activity. ... Huang testified this final part of the process occupied about 20 to 30 minutes of her time using the Clinic internet connection from their residence. ...
TCC
Société de Transport de Laval v. The Queen, 2008 TCC 14
In this connection, I refer to my earlier conclusion that the proportion of use for commercial purposes was 48% in 2000. ... There is no ambiguity about either the purpose of the subsidy or its connection with the contemplated supply. ... In the absence of a contractual relationship between the Appellant and the Ministère des Transports, it is difficult to imagine a more direct connection between the payment (the subsidy) and the supply of a paratransit service for mobility‑impaired persons. ...