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Results 2421 - 2430 of 6321 for connection
TCC
Taylor v. The Queen, 2010 DTC 1189 [at at 3449], 2010 TCC 246
Taylor’s residence in connection with suspected offences under the Income Tax Act ... Gerard Tompkins, was retained a few months later in connection with the objection process ...
SCC
Nowegijick v. The Queen, 83 DTC 5041, [1983] CTC 20, [1983] 1 SCR 29
They import such meanings as "in relation to", "with reference to" or "in connection with". The phrase "in respect of" is probably the widest of any expression intended to convey some connection between two related subject matters. ...
TCC
Coughlan v. The Queen, 2001 DTC 719 (TCC)
Seabright had placed insurance to protect the directors from liability for wrongful acts and defaults alleged against them in connection with their duties as directors. ... I accept the Appellant's evidence that these two amounts, although given as damages for breach of the indemnity and for the loss of insurance benefits, did not fully compensate him for the amounts he spent in connection with the litigation in Ontario and Nova Scotia. [9] Between the years 1989 and 1994, the Appellant spent some $4,725,635 in defence of the Ontario actions and in prosecuting the Nova Scotia actions, and he claimed to be entitled to deduct these amounts in computing his income. ...
TCC
Williams v. The Queen, 2004 DTC 3549, 2004 TCC 706
(f) where the taxpayer was employed in the year in connection with the selling of property or negotiating of contracts for the taxpayer's employer, and (i) under the contract of employment was required to pay the taxpayer's own expenses, (ii) was ordinarily required to carry on the duties of the employment away from the 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 travel expenses in respect of the taxation year that was, by virtue of subparagraph 6(1) (b) (v), not included in computing the taxpayer's income, amounts expended by the taxpayer in the year for the purpose of earning the income from the employment (not exceeding the commissions or other similar amounts referred to in subparagraph (iii) and received by the taxpayer in the year) to the extent that those amounts were not (v) outlays, losses or replacements of capital or payments on account of capital, except as described in paragraph (j), (vi) outlays or expenses that would, by virtue of paragraph 18(1) (l), not be deductible in computing the taxpayer's income for the year if the employment were a business carried on by the taxpayer, or (vii) amounts the payment of which reduced the amount that would otherwise be included in computing the taxpayer's income for the year because of paragraph 6(1) (e); ... ... M.N.R. [4] where he indicated: Dealing firstly with section 8(1) (f) (i), (and I will paraphrase), certain expenses are deductible (by the taxpayer) where they are incurred in connection with the selling of property for his employer and where under the contract of employment the employee was required to pay his own expenses. ...
FCTD
Happy Valley Farms Ltd. v. The Queen, 86 DTC 6421, [1986] 2 CTC 259 (FCTD)
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. 5. ... The Queen, [1978] C.T.C 378; 78 D.T.C. 6281 (F.C.A.), the Chief Justice of the Federal Court stated at 384 (D.T.C. 6285) that the term “secondary intention”:... does no more than refer to a practical approach for determining certain questions that arise in connection with “trading cases” but there is no principle of law that is represented by this tag. ...
TCC
MacMillan Bloedel Ltd. v. R., 97 DTC 1446, [1997] 3 C.T.C. 3012 (TCC), aff'd 99 DTC 5154
All of which is without costs. 2 Accordingly, in connection with those issues set out in the Consent to Judgment, judgment will issue in accordance with the Consent to Judgment filed. 3 The remaining issue deals with a capital loss under subsection 39(2) of the Income Tax Act (the “ Act ”) claimed by the Appellant in its 1987 taxation year. ... In that case, the fluctuations came about in connection with borrowing and repaying. ...
TCC
Louis-Phillipe Bédard v. Minister of National Revenue, 91 DTC 573, [1991] 1 CTC 2323 (TCC)
The relevant passage from that decision is the following (at 2264 (D.T.C. 558)): “The phrase ‘in respect of’ is probably the widest of any expression intended to convey some connection between two related subject matters.” ... Horwitz in his argument had neither acknowledged nor denied that there was any direct connection, chronological or otherwise, between the “ dismissal”, and the "exemplary damages" or the amount for "mental distress". ...
TCC
Donovan v. The Queen, 94 DTC 1143, [1994] 1 CTC 2394 (TCC), aff'd 96 DTC 6085 (FCA)
I come to the conclusion that the value of the benefit is substantial for several different reasons, namely: Firstly There is no connection between the large non-interest bearing loans to Holdings in the years 1986, 1987 and 1988 to the original cost of the house. ... The appellant cannot demonstrate a connection between the original cost of these assets and his shareholder loans in 1986, 1987 and 1988. ...
FCTD
DesChênes v. The Queen, 93 DTC 5234, [1993] 2 CTC 107 (FCTD)
S.C. 1970-71-72, c. 63) (the "Act") and subsequently for the 1983,1984 and 1985 taxation years: 9.(1) Subject to this Part, a taxpayer’s income for a taxation year from a business or property is his profit therefrom for the year. (2) Subject to section 31, a taxpayer’s loss for a taxation year from a business or property is the amount of this loss, if any, for the taxation year from that source computed by applying the provisions of this Act respecting computation of income from that source mutatis mutandis, 18.(1) In computing the income of a taxpayer from a business or property no deduction shall be made in respect of (a) an outlay or expense except to the extent that it was made or incurred by the taxpayer for the purpose of gaining or producing income from the business or property; (h) personal or living expenses of the taxpayer except travelling expenses (including the entire amount expended for meals and lodging) incurred by the taxpayer while away from home in the course of carrying on Pis business; 20.(1) Notwithstanding paragraphs 18(1)(a), (b) and (h), in computing a taxpayer's income for a taxation year from a business or property, 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: (a) such part of the capital cost to the taxpayer of property, or such amount in respect of the capital cost to the taxpayer of property, if any, as is allowed by regulation; 248.(1) In this Act, “business” includes a profession, calling, trade, manufacture or undertaking of any kind whatever and, except for the purposes of paragraph 18(2)(c), an adventure or concern in the nature of trade but does not include an office or employment; "personal or living expenses" includes (a) the expenses of properties maintained by any person for the use or benefit of the taxpayer or any person connected with the taxpayer by blood relationship, marriage or adoption, and not maintained in connection with a business carried on for profit or with a reasonable expectation of profit, (b) the expenses, premiums or other costs of a policy of insurance, annuity contract or other like contract if the proceeds of the policy or contract are payable to or for the benefit of the taxpayer or a person connected with him by blood relationship, marriage or adoption, and (c) expenses of properties maintained by an estate or trust for the benefit of the taxpayer as one of the beneficiaries; The regulations in these income tax appeals are regulations 1100(1)(v), 1100(3), 1101(2a) and 1102(1)(c) of the Income Tax Regulations, as amended for the 1983, 1984 and 1985 taxation 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. ...
FCA
Tory Estate v. M.N.R., 73 DTC 5354, [1973] CTC 434 (FCA), briefly aff'd 76 DTC 6312, [1976] CTC 415 (SCC)
A preliminary point should be mentioned in connection with 1965. As has already been indicated, the assessment was based on the assumption that the appellant purchased a property worth $344,000 from his own company for $259,000 and that payment of the price was effected by the appellant assuming mortgages in the sum of $311,000 and being given back a promissory note for $53,000. ... The question of benefit or no benefit in the 1965 taxation year is, in my view, primarily a question of fact in connection with which the onus of proof was on the appellant. ...