Search - connection

Filter by Type:

Results 2401 - 2410 of 6319 for connection
FCTD

The Queen v. Dorchester Drummond Corp. Ltd., 79 DTC 5163, [1979] CTC 219 (FCTD)

It is never necessary to show a causal connection between an expenditure and a receipt. ... In the three following years he claimed as deductions from other income his taxes, insurance and other expenses in connection with his property. ...
TCC

Hamilton v. The Queen, 97 DTC 787, [1997] 1 CTC 2446 (TCC)

He had used his ingenuity, connections and enthusiasm to form syndicates and raise necessary capital. ... In determining whether the lease rental payments qualified as a CEE on page 188 (D.T.C. 6127) in Gulf Canada (supra) the Federal Court of Appeal concluded that payments made to maintain an acreage inventory upon which development and production may take place in the future are not within the definition of clause 66.1(6)(a)(i) In order for an expense to be incurred there has to be some connection between that expense and the work actually done on the ground. ...
FCA

Indalex Ltd. v. The Queen, [1988] 1 CTC 60, 88 DTC 6053 (FCA)

That conclusion was characterized as a major error since, it was said, all of the evidence demonstrated hard bargaining including the uncontradicted, unimpugned testimony of three witnesses who had, at the time of the trial, severed all connections with the Pillar group. ... Stracey, who had not severed his connection with the group, who said, for example, at Transcript, Vol. 2. p. 269, lines 27 to 30, under cross-examination, Whether you use the words bargain, talk or negotiate I am telling you under oath that I did my very best at all times to get the best possible price I could from Pillar International. ...
FCA

Desnomie v. Canada, 2000 DTC 6250 (FCA)

There is no connection here between the appellant's employment income and the Peepeekisis Reserve in Saskatchewan. [19]      The necessity argument is based on the connection between the MIEA and the services performed by the appellant on the one hand, and students from various reserves in Manitoba on the other. ...
FCA

Ludmer v. The Queen, 95 DTC 5311, [1996] 3 CTC 74 (FCA)

.); affirmed [1989] 1 S.C.R. 141, 91 N.R. 63 Lacombe J.A. said the following (at pages 88-9 (N.R. 218): In accepting the applicant’s argument of estoppel by representation on grounds of equity, the Court would thereby be setting aside the decision of the respondent Commission rather than that of the Umpire, and the Court is not sitting in equity in connection with the remedy currently being sought by the applicant. ... If by chance the appellants were allowed to call as witnesses taxpayers whom they knew or thought they knew had benefited from preferential treatment by the Minister it can be seen what an unfavourable position the latter would be placed in, as he could in no case present opposing evidence since he is firmly bound by the prohibition imposed on him against directly or indirectly disclosing the secret information he has in this connection. ...
TCC

G.A. Borstad Associates Ltd. v. MNR, 92 DTC 1743, [1992] 2 CTC 2146 (TCC)

In this connection, it is to be noted that in many provisions of the Income Tax Act the deduction or non-deduction of a particular type of expense is stated in terms of both an expense made or incurred. ... In this connection, it is particularly instructive to consider the language used in the provisions of paragraph 20(1)(c) and section 78 of the Income Tax Act. ...
FCTD

Bigelow v. The Queen, 90 DTC 6262, [1990] 1 CTC 351 (FCTD)

Bigelow, deducted losses incurred in connection with his raising of thoroughbred race horses in 1977, 1978 and 1979 in calculating his income tax for those years. ... See also paragraph 139(1)(ae) of the Income Tax Act which includes as "personal and living expenses" and therefore not deductible for tax purposes 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. ...
SCC

Guay v. Lafleur, 64 DTC 5218, [1964] CTC 350, [1965] SCR 12

John or the Vancouver company and from making any finding or report to the Attorney-General in connection therewith on the ground that he had not given notice to St. ... Davis, J. said, at page 452: “Fundamentally, the investigator in this case was an administrative officer, and the machinery set up by the statute was administrative for the purpose of enquiring as to whether or not fraudulent practices had been or were being carried on in connection with the sale of the securities of the Wayside Company. ’ ’ In the present case, I am in agreement with my brother Abbott in holding as did Hyde and Montgomery, J J. that this investigation is a purely administrative matter which can neither decide nor adjudicate upon anything. ...
TCC

Audet v. The Queen, 2012 DTC 1208 [at at 3556], 2012 TCC 162 (Informal Procedure)

Accordingly, a deduction cannot be so far removed from its corresponding income stream as to render its connection to the anticipated income tenuous at best (Byram, at paragraphs 21 and 23). In other words, if the connection between the anticipated income and the expense is too tenuous or remote, it cannot be argued that the expense was incurred to gain or produce income from the business or property ...
TCC

Falkener v. The Queen, 2007 DTC 1470, 2007 TCC 514 (Informal Procedure)

See also s. 139(1)(a) of the Income Tax Act which includes as "personal and living expenses" and therefore not deductible for tax purposes, 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. ... The Appellant’s reported losses in the farming enterprise, after inventory adjustment, and his net income from his insurance adjusting work (is) are the following:     Farming loss Insurance adjusting net income   1998 ($35,936) $82,207 1999 (38,471) 69,818 2000 (32,885) 43,707 2001 (25,778) 101,136 2002 (110,801) 81,359 2003 (390) 91,845   [16]     Several things need to be noted in connection with these results. ...

Pages