Search - connection

He explained that it was during an audit of the Restaurants Marie-Antoinette, when he requested documentation for a payment of $10,000, that he was told that the amount had been paid to a firm of lawyers in connection with the appellant’s dismissal. ...

Work expended on or in connection with the property realized. If effort is put into bringing the property into a more marketable condition during the ownership of the taxpayer or if special efforts are made to find or attract purchasers (such as the opening of an office or advertising) there is some evidence of dealing in the property. ...

. — where the taxpayer was employed in the year in connection with the selling of property or negotiating of contracts for his employer, and (i) under the contract of employment was required to pay his own expenses, (ii) was ordinarily required to carry on the duties of his employment away from his employer’s place of business, (iii) was remunerated in whole or part by commissions or other similar amounts fixed by reference to the volume of the sales made or the contracts negotiated, and (iv) was not in receipt of an allowance for travelling expenses in respect of the taxation year that was, by virtue of subparagraph 6(l)(b)(v), not included in computing his income, amounts expended by him in the year for the purpose of earning the income from the employment (not exceeding the commissions or other similar amounts fixed as aforesaid received by him in the year) to the extent that such amounts were not (v) outlays, losses or replacements of capital or payments on account of capital, except as described in paragraph (j), or (vi) outlays or expenses that would, by virtue of paragraph 18(1)(1), not be deductible in computing the taxpayer’s income for the year if the employment were a business carried on by him; 18. ...

An overview of all the factors that the Court must look at in determining whether a primary or a secondary intention is, as a question of fact, to be determined in each case and a list of those factors include the nature of the property acquired, the length of period of ownership of the property, the frequency or number of similar transactions, the corporate structure and activities of the taxpayer, how the taxpayer dealt with the asset, the property transaction history of the taxpayer, the ability of the taxpayer to finance the undertaking, the feasibility of the project, market conditions, how the taxpayer dealt in the marketplace, the work expended on or in connection with the property realized and the circumstances responsible for the sale of the property. ...

Negm agreed that this was a project which could meet the Department’s requirements in its evaluation of SR & ED activities in connection with technological uncertainties, technological breakthroughs and technological content. ...

The expenses of properties maintained by the taxpayer for his own use and benefit, and not maintained in connection with a business carried on for profit or with a reasonable expectation of profit are not deductible. ...

The full salaries paid to Daniel Dumont and Alain Laferrière in connection with their employment with the appellant were paid for their involvement in scientific research and experimental development by the appellant; 7. ...

There is a direct connection, like one led to the other.” In the course of cross-examination it was pointed out that the appellant filed his return for 1995 at the end of April 1996 which was after the March 19, 1996 meeting with Mary Minigan and Terence Law. ...

Considerations include time spent, motives or reasons, dwelling establishment, background, mode or routine of life and connections with homes and family. ...

, which reads as follows: (12) Notwithstanding any other provision of this Act, in computing an individual’s income from a business for a taxation year, (b) where the conditions set out in subparagraph (a)(i) or (ii) are met, the amount for the work space that is deductible in computing the individual’s income from the business for a taxation year shall not exceed the individual’s income from the business for the year, computed without reference to the amount; With respect to the expenses incurred for the newspaper, magazine and periodical subscriptions, the appellant simply stated that these expenses were necessary in order to carry on his profession as a writer; that is not sufficient justification, and moreover, no evidence was presented to show the connection between the applicability of these expenses and the profession of writer. ...