Search - connection

There was no evidence to suggest that he had purchased properties other than 310 Cranston Park and the Property. [41]   Before he secured stable employment with the TTC, the Appellant did an eclectic series of jobs, none of which had a close connection to real estate transactions. ... Their father’s occupation as a cabinet maker is related to residential and/or commercial interiors, but the connection to real estate transactions is remote. [43]   Therefore, this factor favors a finding on account of capital. (3) The nature of the property and the use made of it by the taxpayer [44]   The Property is a residential apartment-style condominium which sold relatively quickly after it was listed. ...

Justice Simpson concluded that the presumption of receipt had not been rebutted and, consequently, dismissed the application for judicial review. [25]   In Wu v Canada (Citizenship and Immigration), 2018 FC 554 [Wu], an immigration officer requested in a letter sent by e-mail that the applicant attend an interview in connection with her application for permanent residence. ... In allowing the application, Justice Gascon found there was no evidence to reasonably determine that the refusal decision had been sent on either July 14, 2016 or November 30, 2016. [27]   In Lu v Canada (Citizenship and Immigration), 2018 FC 1149, the applicants failed to respond to a procedural fairness letter allegedly sent to them via e-mail in connection with their application for permanent residence. ...

Zuniga’s persistent threats and connections with criminal organizations. ... Zuniga’s violent past, criminal connections, and continued threats against the Applicant. ...

In connection with the intervention, the Minister filed information indicating that the U.S. ... He testified that when he originally filled out documents in connection with his refugee claim he made mistakes about his travel route to Canada and the name on the passport he had used because he was scared and his mind was “all over the place.”   ...

Diallo in order to kill him in connection with political activities in 2013. (3) Mr.  ... For all these reasons, I am not satisfied that the applicant is at risk in connection with his political involvement. [22]   The Respondent submits that the Officer considered all of Mr.  ...

The CRA subsequently also denied these objections, taking the position that no ETA provision permits fuel tax refunds. [12]   CPR thus seeks repayment of these fuel tax refunds in this action, as well as a declaration that the CRA is not entitled to collect fuel taxes on fuel purchased, consumed, or used in connection with CPR’s main line. ... In addition, CPR seeks a declaration that the Crown cannot collect tax imposed under the ITA on income earned by CPR in connection with the operation of its railway as originally defined in the CPR Act. [13]   CPR alleges that the imposition of both taxes are wrongful breaches of (i) the Contract, (ii) the CPR Act, (iii) the CPR Charter, and (iv) the Constitution of Canada, for which CPR has filed a Notice of Constitutional Question in accordance with the Federal Courts Act, RSC, 1985, c F-7 [FC Act] and FC Rules. ...

Ciciarelli did not file notices of objection to the assessments. [5]   In connection with the CRA’s collection actions regarding Mr. ... Ciciarelli’s significant prior non-compliance with the ITA and Orders of this Court made in connection with the CRA’s audits of his other business interests warrant an order requiring delivery of the Material to the CRA. ...

In connection with paragraph 3 above, the parties each desire to find a valuation method, other than the deductive method and preferably the computed value if applicable, by which the value for duty of Pier 1’s goods may be ascertained from the period beginning March 3, 2002. In the event that the deductive or a modified or residual deductive method of valuation becomes the only viable means of determining the value for duty of Pier 1’s goods the CCRA agrees that it will not deny expenses incurred in connection with the sale in Canada of the goods being valued solely on the basis that the expenses were paid to a non-Canadian entity; and … (underlining added) [6]   In accordance with the settlement agreement, after a fresh audit, a Customs Valuation Report was issued which established that Pier 1 was not required to utilize the deductive valuation method, and could instead apply a modified version of the computed value method. ...

He did not establish any connection between the total amount of the alleged gifts and the total amount of deposits to his personal bank accounts in 2013 and 2014. d)   Mr. ... Conclusion [30]   It is unlikely that a taxpayer who was in a position to make an equalization payment of $425,000 between 2012 and 2014 would have earned less than $11,000 in 2013 and less than $25,000 in 2014. [31]   In this connection, it is worth recalling why Mr. ...

The statement also shows that in the meantime he had received $330 in connection with a road allowance. ... In his evidence, he stated that his income, as reported in his income tax returns, was correct, and he produced a large number of vouchers relating to receipts of income and disbursements in connection with the operation of the farm for each of the years in question. ...