Search - connection

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. ...

The appellant also lives on the reserve which buttresses the connection to the reserve through his employment. ... By definition it may be that there was a cultural connection between the services of the employer and the residents of the reserve, however, there is no specific evidence to support this position. ...

Factual background   [27]     The background to this matter was provided in testimony from two officials of the Canada Revenue Agency: Scott Arner, who performed the GST audit, and John Possmayer, who subsequently performed an investigation that led to criminal charges being laid against the appellants in connection with the ITC claims ...   [33]     At the criminal hearing, it was acknowledged that civil proceedings were underway in connection with the assessments as well ...

Another instance of executor time being spent on the question of the extent of the entitlement of each beneficiary arose in connection with the U.S. bank accounts. ... Finally, I turn to the deductibility of costs incurred in connection with the investment of liquid assets. ...

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. ...

The purposes and objects of said corporation as set out in its Letters Patent are as follows: (a) To carry on, whether as principals or agents, the business of an investment company and, in that connection, to purchase, underwrite, take in exchange, subscribe for or otherwise acquire upon and subject to such terms and conditions as may seem expedient, hold, sell, alienate and otherwise dispose of shares, stocks, bonds, debentures, debenture stock, warrants, option certificates or other evidences of indebtedness, securities and investments of every kind and to manage, sell, alienate or otherwise dispose of any of the assets of the Company from time to time and generally to make investments of the funds or moneys of the Company in any kind of property, real and immoveable, personal and moveable, and to change, alter, vary or realize upon any investments from time to time and to reinvest the proceeds thereof. ... The relevant portions of this Agreement read as follows: WHEREAS the Purchaser is a wholly owned subsidiary of the Vendor and has been formed for the purpose of taking over and carrying on the mining exploration and development work of the Vendor, and will reimburse the Vendor for all expenditures made by it in that connection, the whole with the same effect and to the same extent as though such exploration and development work had always been carried on by the Purchaser. ...

Counsel for the Minister argued that the courses the Appellant took had no connection to the Canadian campuses, which she did not attend, and therefore the tuition fees paid for those courses is not deductible under paragraph 118.5(1)(a) of the Act ... Subsection 118.6(1) states, in part:   118.6(1) Definitions    For the purposes of sections 63 and 64 and this subdivision,   “designated educational institution” – “designated educational institution” means               (a) an educational institution in Canada that is               (i) a university, college or other educational institution designated by the Lieutenant Governor in Council of a province as a specified educational institution under the Canada Student Loans Act, designated by an appropriate authority under the Canada Student Financial Assistance Act, or designated by the Minister of Higher Education and Science of the Province of Quebec …, or               (ii) certified by the Minister of Human Resources and Skills Development to be an educational institution providing courses, other than courses designed for university credit, that furnish a person with skills for, or improve a person’s skills in, an occupation,               (b) a university outside Canada at which the individual referred to in subsection (2) was enrolled in a course, of not less than 13 consecutive weeks duration, leading to a degree, or   …   [18]          The Act provides an expansive definition of “ Canada ” in section 255, which states:   SECTION 255:   Canada               For the purposes of this Act, “ Canada ” is hereby declared to include and to have always included               (a) the sea bed and subsoil of the submarine areas adjacent to the coasts of Canada in respect of which the Government of Canada or of a province grants a right, licence or privilege to explore for, drill for or take any minerals, petroleum, natural gas or any related hydrocarbons; and               (b) the seas and airspace above the submarine areas referred to in paragraph (a) in respect of any activities carried on in connection with the exploration for or exploitation of the minerals, petroleum, natural gas or hydrocarbons referred to in that paragraph ...

The duty of the Court is, in my opinion, in all cases the same, whether the Act to be construed relates to taxation or to any other subject, namely to give effect to the intention of the Legislature as that intention is to be gathered from the language employed having regard to the context in connection with which it is employed. ... In this connection it relies upon the well-known maxim of statutory interpretation expressio unius est exclusio alterius. ...

Further, the appellants contend that interest expenses incurred by them during the 1982 taxation year relating to advances to Eletex to permit Eletex to discharge its obligation to the CIBC are deductible from their income from Bathurst notwithstanding Eletex’s bankruptcy because Eletex was simply an offshoot of Bathurst and income and losses realized in connection with it formed part of the same source of income. ... Earlier, at page 343 (D.T.C. 1243), his Lordship in denying a deduction for interest on money lent by the appellant corporation to its subsidiary had this to say: No doubt there is in fact a casual connection between the purchase of the stock and the benefits ultimately received; but the statutory language cannot be extended to such a remote consequence; it could be carried to any length in a chain of subsidiaries; and to say that such a thing was envisioned by the ordinary expression used in the statute is to speculate and not interpret. ...

The appellant performed his duties in connection with a contract made between the province, as executing agency, and the Canadian International Development Agency (“CIDA”), an agency of the Government of Canada’s Department of External Affairs. ... (a) was employed by a person who was a specified employer, and (b) performed all or substantially all the duties of his employment in one or more countries other than Canada (i) in connection with a contract under which the specified employer carried on business in such country or countries with respect to (A) the exploration for, or exploitation of, petroleum, natural gas, minerals or other similar resources. ...