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TCC

Onuma v. Human Resources, 2007 TCC 638

The term has a strong connection with lodging, and that is why it is usually associated with the provision of meals on a daily basis ...
TCC

Williston v. The Queen, 2007 TCC 412 (Informal Procedure)

I do not find that high degree of negligence in connection with the misstatements of business income. …   I find this comment applies equally to the Appellant in the present circumstances and, therefore, penalties pursuant to subsection 163(2) only are not to be imposed ...
TCC

DeCicco v. The Queen, 2007 TCC 67

REASONS FOR JUDGMENT Woods J. [1]      The appellant, Tony DeCicco, paid an amount of $87,500 on account of a guarantee provided to The Manufacturers Life Insurance Company ("Manulife") in connection with a refinancing for a strip mall in which a corporation related to the appellant had a 25 percent interest. [2]      The appellant seeks to deduct this amount as a business expense in computing his income for the 2000 taxation year. ...
TCC

Ouahidi c. La Reine, 2007 TCC 119 (Informal Procedure)

Ouahidi's appeal is allowed with costs (with the exception of the expert fees, because they were incurred in connection with other court proceedings) and the assessment is vacated ...
TCC

Brigadier Security Systems (2000) Ltd. v. M.N.R., 2007 TCC 526

Babiy was also entitled to and did find his own clients, contacts he made through cold calls, business connections, family or friends. ...
TCC

Beutler Hands on Massage v. The Queen, 2007 TCC 371 (Informal Procedure)

"taxable supply" means a supply that is made in the course of a commercial activity;   [7]      Necessary to the understanding of "taxable supply" is the relevant portion of the definition of "commercial activity":   123(1)  "commercial activity" of a person means   (a) business carried on by the person (other than a business carried on without a reasonable expectation of profit by an individual, a personal trust or a partnership, all of the members of which are individuals), except to the extent to which the business involves the making of exempt supplies by the person,   (b) an adventure or concern of the person in the nature of trade (other than an adventure or concern engaged in without a reasonable expectation of profit by an individual, a personal trust or a partnership, all of the members of which are individuals), except to the extent to which the adventure or concern involves the making of exempt supplies by the person, and   (c) the making of a supply (other than an exempt supply) by the person of real property of the person, including anything done by the person in the course of or in connection with the making of the supply;   [8]      To this point, the evidence is clear that the Appellant was making a supply of massage services in the course of carrying on its business. ...
TCC

Mochizuki v. The Queen, 2008 TCC 526

He has been unable to draw any cohesive connection. I would strike the Notice of Appeal on the basis that it is plain and obvious it cannot be successful ...
TCC

Fiducie Chry-Ca v. The Queen, 2008 TCC 423 (Informal Procedure)

(c)               On October 5, 2005, the Appellant filed a new residential rental property GST rebate application with the Minister in connection with the triplex at 1638-1642 Charles Street, Saint-Hubert, Quebec. ...
TCC

Leckie Morel v. The Queen, 2008 TCC 433

  [3]      The appeals are concerned with the appellants’ claims that they are entitled to deductions in computing their income for losses sustained by certain limited partnerships during the years under appeal, and for interest paid in connection with their acquisition of their partnership interests ...
TCC

9006-3611 Québec Inc v. M.N.R., 2008 TCC 9

    [8]      I would note that the Minister's decision that the worker accumulated 1334 hours of insurable employment according to sections 9.1 and 9.2 of the Employment Insurance Regulations, and that the worker's insurable earnings amounted to $9,067.72 according to section 2 of the Insurable Earnings and Collection of Premiums Regulations, essentially relied on the truth and accuracy of the notebooks in which the Worker allegedly entered the hours that she actually worked and the remuneration that she actually received from the Appellant in connection with her employment ...

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