Search - connection

Taxable supply means a supply that is made in the course of a commercial activity, according to the definition of this expression in subsection 123(1) of the Act. [15]         The expression “commercial activity” is also defined in subsection 123(1) of the Act, which states the following: “commercial activity” of a person means (a) a business carried on by the person (other than a business carried on without a reasonable expectation of profit by an individual, a personal trust or a partnership, all of the members of which are individuals), except to the extent to which the business involves the making of exempt supplies by the person, (b) an adventure or concern of the person in the nature of trade (other than an adventure or concern engaged in without a reasonable expectation of profit by an individual, a personal trust or a partnership, all of the members of which are individuals), except to the extent to which the adventure or concern involves the making of exempt supplies by the person, and (c) the making of a supply (other than an exempt supply) by the person of real property of the person, including anything done by the person in the course of or in connection with the making of the supply; [16]         By that definition, the making of exempt supplies is excluded from commercial activity. [17]         Subsection 9(2) of Part I of Schedule V sets out that the sale of real property by an individual is an exempt supply, except in the circumstances listed in subsections 9(2)(a) to (f). [18]         One of the exceptions, at subparagraph 9(2)(b)(ii) of Part I of Schedule V of the Act, sets out that the supply of real property made in the course of an adventure or concern in the nature of trade is not an exempt supply if the individual filed an election with the Minister containing prescribed information. ...

Feil’s corporation was a member of Feil & Co. and that Feil & Co. would have been aware through this connection that the Corporation Sole was just a conduit. [28]         I would conclude that the respondent was correct to conclude that the cheques written by Feil & Co. were in fact payments to Mr. ...

The Deputy Attorney General relies on the following additional facts: a)         in April 2014, as a result of an investigation of the XXX Tax Shelter by the Royal Canadian Mounted Police ("RCMP"), principals and representatives of XXX and ABC ( … ) were charged with the following offences in relation to their activities in connection with the XXX Tax Shelter: •          fraud over $5,000.00 contrary to paragraph 380(1)(a) of the Ciminal Code; •          conspiracy to commit fraud over $5,000.00 contrary to paragraph 465(1)(c) of the Criminal Code; •          laundering proceeds of crime contrary to subsection 462.31(1) of the Ciminal Code; and •          commission of an offence for the benefit for a criminal organization contrary to section 467.12 of the Criminal Code. [3]              The charges listed in Bullets 2 and 3 were not in fact laid against the individuals and representatives of XXX. [4]              I granted the appellant's motion to strike paragraph 76 from the respondent's pleadings on the basis the paragraph's contents were scandalous and an abuse of the process of the Court: Rules 53(1)(b) and (c), as well as potentially prejudicing or delaying the fair hearing of the trial: Rule 53(1)(a) of the Rules. [5]              In short, the persons referred to in paragraph 76 of the reply were charged with offences under the Criminal Code but not convicted of any charges. ...

The Appeal [9]              Paragraph 8(1)(c) of the Income Tax Act (“ ITA ”) reads:   (1) Deductions allowed-- In computing a taxpayer 's income for a taxation year from an office or employment, there may be deducted such of the following amounts as are wholly applicable to that source or such part of the following amounts as may reasonably be regarded as applicable thereto:   (c) clergy residence-- where, in the year, the taxpayer   (i) is a member of the clergy or of a religious order or a regular minister of a religious denomination, and   (ii) is   (A) in charge of a diocese, parish or congregation,   (B) ministering to a diocese, parish or congregation, or   (C) engaged exclusively in full-time administrative service by appointment of a religious order or religious denomination,   the amount, not exceeding the taxpayer 's remuneration for the year from the office or employment, equal to   (iii) the total of all amounts including amounts in respect of utilities, included in computing the taxpayer 's income for the year under section 6 in respect of the residence or other living accommodation occupied by the taxpayer in the course of, or because of, the taxpayer 's office or employment as such a member or minister so in charge of or ministering to a diocese, parish or congregation, or so engaged in such administrative service, or   (iv) rent and utilities paid by the taxpayer for the taxpayer 's principal place of residence (or other principal living accommodation), ordinarily occupied during the year by the taxpayer, or the fair rental value of such a residence (or other living accommodation), including utilities, owned by the taxpayer or the taxpayer 's spouse or common-law partner, not exceeding the lesser of   (A) the greater of   (I) $1,000 multiplied by the number of months (to a maximum of ten) in the year, during which the taxpayer is a person described in subparagraphs (i) and (ii), and   (II) one-third of the taxpayer 's remuneration for the year from the office or employment, and   (B) the amount, if any, by which   (I) the rent paid or the fair rental value of the residence or living accommodation, including utilities   exceeds   (II) the total of all amounts each of which is an amount deducted, in connection with the same accommodation or residence, in computing an individual 's income for the year from an office or employment or from a business (other than an amount deducted under this paragraph by the taxpayer), to the extent that the amount can reasonably be considered to relate to the period, or a portion of the period, in respect of which an amount is claimed by the taxpayer under this paragraph; [10]         At the hearing, the Appellant stated that he satisfied the conditions given in paragraph 8 (1)(c) of the ITA. ...

  [14]         The Respondent did not question the Appellant’s numbers in connection with the CCA other than an addition of $29,149 back in 2003 to Class 10: the Appellant only sought an addition of $9,798. ...

The walls of each of those rooms were rebuilt and the bathroom and powder room floors were rebuilt;  -    rebuilt the foundation and added a cement floor to replace the dirt floor in the basement;  -    changed the electrical connection point and the heating system ...

The Applicant has brought contempt proceedings in connection with the Respondent's compliance with that decision. ...

Inuit Tapirisat, [1980] 2 S.C.R. 735, that a statement of claim cannot be struck out unless it is plain and obvious that it discloses no reasonable cause of action. [3]      In the case at bar, these limits are a sort of yoke the defendant must wear in connection with his motion. ...

She deposed she did not make any notes of any conversations with other Agency officials she had in connection with the Richards file. ...

In that connection, she identified the applicant's spouse's 1991 tax return was reassessed in 1999 to yield a positive credit. ...