Search - connection

Filter by Type:

Results 2441 - 2450 of 6336 for connection
TCC

Stone Container (Canada) Inc. v. R., 98 DTC 1508, [1998] 3 CTC 2150 (TCC)

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. ...
EC decision

MNR v. Ontario Paper Co. Ltd., 58 DTC 1046, [1958] CTC 71 (Ex Ct), briefly aff'd 59 DTC 1327 (SCC)

In this connection, Lord Herschell, in Bank of England v. Vagliano, [1891] A.C. 107, 145, said: ‘‘ What, however, I am venturing to insist upon is, that the first step taken should be to interpret the language of the statute...” ... In this connection, Odgers at page 177 (supra) states: 44 Next, if possible, the construction adopted should be in accordance with the policy and object of the statute in question.’’ ...
TCC

830480 Alberta Inc. v. The Queen, 2013 DTC 1027 [at at 132], 2012 TCC 424

That question does not arise only in connection with strict liability offences, although with the growth in regulations and the multiplication of statutory offences the field of strict liability has proven to be the most fertile for the emergence of this defence. ... ]   [26]         I agree with counsel’s submission that a taxpayer can avoid late filing penalties if the taxpayer can show, on a balance of probabilities, that he or she had reasonable grounds to believe that no taxes were owed in connection with the returns that were filed late. ...
TCC

Galaxy Management Ltd. v. The Queen, 2005 DTC 1558, 2005 TCC 674

Both appear to have been cobbled together using inappropriate precedents. [18]     The agency agreement between Galaxy and Fountain Set contains the following terms among others: 1.1        The Principal hereby engages and appoints the Agent as an agent on the sales of their fabric products in Western Canada. 1.2        The Agent accepts such appointment and agrees to keep and perform all the duties and obligations under the terms and conditions of this Agreement. 2.1        The term of the employment shall commence from the 1st day of September 1998 and continue unless terminated earlier by either party. 3.0        Services 3.1        The Employee shall: (a)         devote sufficient time, attention, skills and efforts in connection with the Principal's business, and comply with all instructions, directions, request, rules and regulations made and issued by the Principal; (b)         perform services conscientiously and to the full limit of his ability at all times and whenever and wherever required and desired by the Principal; (c)         carry out faithfully such duties and exercise such powers form time to time as the Principal may prescribe; 4.0        Compensation 4.1        Providing the Agent fulfills his obligations under this Agreement, and as full consideration for all services rendered or to be rendered to the Principal, the Principal shall pay the Agent a commission of 1.5% on the sales of the fabric products contributed to the Principal and the Principal will release the compensation to the Agent on a monthly basis. 4.2        The Agent agrees that the Principal may deduct and withhold from the compensation payable to the Agent under the provisions of any statute, regulation or order and any and all amendments thereto requiring the withholding or deduction of compensation. 4.3        The Agent shall be responsible for all expenses in connection with the services rendered under this Agreement. 4.4.       ...
TCC

Giguere v. The Queen, 2005 DTC 646, 2005 TCC 257

Accordingly, the Southwind factors are useful in analyzing whether there exists, on the facts of this particular case, a connection between the Appellants' admittedly off-reserve business activities and the Thessalon Reserve so as to render their business income exempt from taxation under section 87. (1)      the location of the business activities; [17]     Since 1992, the business address of Clara Giguere Trucking and William Giguere Trucking David Giguere has been the Thessalon Reserve. ... This is not particularly significant as even if the Appellants had lived on the Thessalon Reserve for the entire period, that in itself would not outweigh the other factors pointing to a lack of connection between the businesses and the reserve. [26]     To summarize, the business activities of William Giguere and Clara Giguere were such that they could only be accomplished off-reserve, almost completely in a context not "integrated into reserve life" as described in Recalma: their customer, Meakin Forest, was located off the reserve. ...
FCA

Alberta Institute on Mental Retardation v. The Queen, 87 DTC 5306, [1987] 2 CTC 70 (FCA)

(j) “related business" — “related business” in relation to a charity includes a business that is unrelated to the objects of the charity if substantially all of the people employed by the charity in the carrying on of that business are not remunerated for such employment; [Emphasis added.] 149.1(2) Revocation of registration of charitable organization — The Minister may, in the manner described in section 168, revoke the registration of a charitable organization for any reason described in subsection (1) of that section or where the organization (a) carries on a business that is not a related business of that charity; or (b) fails to expend in any taxation year, on charitable activities carried on by it and by way of gifts made by it to qualified donees, amounts that, in the aggregate, are at least equal to the amount that would be determined for the year under subparagraph (1)(e)(i) in respect of the organization if it were a charitable foundation. (3) Revocation of registration of public foundation — The Minister may, in the manner described in section 168, revoke the registration of a public foundation for any reason described in subsection (1) of that section or where the foundation (a) carries on a business that is not a related business of that charity; (b) fails to expend in any taxation year, on charitable activities carried on by it and by way of gifts made by it to qualified donees, amounts that, in the aggregate, are at least equal to its disbursement quota for that year; (c) since June 1, 1950, acquired control of any corporation; (d) since June 1, 1950, incurred debts, other than debts for current operating expenses, debts incurred in connection with the purchase and sale of investments and debts incurred in the course of administering charitable activities; or (e) at any time within the 24 month period preceding the day on which notice is given to the public foundation by the Minister pursuant to subsection 168(1) and at a time when the public foundation was a private foundation, took any action or failed to expend amounts such that the Minister was entitled, pursuant to subsection (4), to revoke its registration as a private foundation. ... Accordingly, the commercial activity has a very close connection with the charity. ...
EC decision

Grader v. MNR, 62 DTC 1070, [1962] CTC 128 (Ex Ct)

On cross-examination the witness admitted that he had no experience in connection with the sale of theatres and had no financial interest in any theatre companies. He agreed, however, that in connection with theatres goodwill is the most important thing and that he had never attempted to appraise the goodwill of the appellant’s theatre. ...
TCC

Morisset c. La Reine, 2008 DTC 3864, 2006 TCC 483

A chiropractor performs and prescribes tests, examinations and analyses of the patient's state of health to assess the appropriateness and efficacy of the chiropractor’s treatment or in connection with the chiropractor’s illness prevention program. ... A chiropractor advises professionals concerned with the workplace, or with the prevention of accidents on duty or work-related illnesses, or the prevention of traffic accidents, and performs assessments in connection with these matters.  ...   12. ...
TCC

Bernier v. The Queen, 2004 DTC 3235, 2004 TCC 376

In 1998, he paid $29,755.33 in interest in connection with a line of credit, and he claimed an equivalent deduction in calculating his business income.  The Minister of National Revenue disallowed the deduction, because the interest had not been paid in connection with a loan used for the purpose of earning income from a business or property.  ...
TCC

Donato v. The Queen, 2009 DTC 1384 [at at 2111], 2009 TCC 590

Through that connection, he decided to make a charitable donation of a large portion of his cartoon collection to that institution. ... ”   [50]     Based on the evidence, the tangible works of art were used in connection with the Sun Media contract, and this was the primary use of this property. ...

Pages