Search - connection

Many of the expenses incurred, such as for computers and internet connections, are consistent with either business or personal use ...

Moreover, S erge Bastien, as the person duly authorized by the National Bank's board of directors, signed on the bank's behalf the subrogation document in favour of the appellants, and the National Bank is named as the [TRANSLATION] "original plaintiff" in the appearance filed in connection with the continuance of suit (Exhibit A‑1, Tab 12) ...

Grant contends that the amount represents damages that were not in respect of a loss of employment, but were in connection with a wrong arising from misrepresentations made by his former employer, Weyerhaeuser Canada (“Weyerhaeuser”) ...

  [27]          For all these reasons, then, I find that the TQI activities undertaken by Logitek in its 2000 taxation year in connection with the L’eBiz project do not qualify for investment tax credits ...

Naeini’s testimony that the money flowed through Dubai, I conclude International Media Services has some Dubai connection. ...

The Minister also deemed that the Appellant was dealing with the Worker at arm's length in connection with his employment, because he was satisfied that it was reasonable to conclude that the Appellant and the Worker would have entered into a substantially similar contract of employment if they had been dealing with each other at arm's length having regard to the following circumstances:         (a)  In 2006, the Worker's weekly pay was the same as his brother Simon's, and less than Yvan's ($1,100 per week). ...

  [30]     In other words, he used invoices that had absolutely no connection with the application for subsidization. ...

(s)        The worker also lent the Appellant $6,000 without drafting documents in connection with the loan.    ...

As counsel for the Appellant noted in her submissions, I made reference in my Reasons for Judgment to the upshot of the Respondent's having pleaded assumptions not, in fact, made: [26]       Counsel for the Respondent argued that exactly such a connection existed between Tiburzi and Gelder: "--- they have trusted each other. ...

(ii)         office rent, or salary to an assistant or substitute, the payment of which by the officer or employee was required by the contract of employment, (iii)        the cost of supplies that were consumed directly in the performance of the duties of the office or employment and that the officer or employee was required by the contract of employment to supply and pay for. [3]      Paragraph 8(10) of the Act reads as follows: (10)       Certificate of employer- An amount otherwise deductible for a taxation year under paragraph (1)(c), (f), (h) or (h.1) or subparagraph (1)(i)(ii) or (iii) by a taxpayer shall not be deducted unless a prescribed form, signed by the taxpayer's employer certifying that the conditions set out in the applicable provision were met in the year in respect of the taxpayer, is filed with the taxpayer's return of income for the year. [4]      Paragraph 8(1)(f) of the Act reads as follows: (f)         Sales expenses [of commission employee]- 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 such amounts were not... [5]      With regard to paragraph (8)(1)(f) of the Act, amounts exceeding the amounts of commissions or other similar amounts have already been allowed as deductions in the calculation of the Appellant's employment income (as will be seen in the next paragraph of these reasons), therefore that provision can no longer have any application. ...