Search - connection

Property used to manufacture or process goods to be supplied in connection with the provision of a service, namely through a contract for work and materials, is not viewed as being used directly or indirectly in Canada primarily in the manufacturing or processing of goods for sale, and as such, does not qualify for either the accelerated capital cost allowance or the investment tax credit. 21        The Crown Tire case related to whether the application of treads manufactured by the taxpayer to tires brought in by customers for repair constituted the manufacture or processing of goods for sale.    ...

" Respondent's counsel, still in connection with the second point, said: There are certain administrative practices, information circulars and information bulletins, information circulars, and the understanding of the tax community of what constitutes a notice of loss determination. [18]     He then stated that the question of what constitutes a notice of loss determination is, in part, a question of fact on which evidence would have to be introduced. ...

Mathar; (k)         The appellant incurred no rental expenses for each of the years at issue; (l)          The Minister disallowed the appellant the rental expense of $2,000 per year for each of the years at issue; (m)        For the 1997, 1998 and 1999 taxation years, the appellant also claimed the amounts of $2,312, $2,270 and $1,840, respectively, as home office expenses for his Eaton residence; (n)         The appellant did not have a space reserved for working at home and did not receive clients there; (o)         The home office expenses were disallowed by the Minister for the 1997, 1998 and 1999 taxation years; (p)         With reference to the expenses in connection with the bed and breakfast, "L'Imprévu", the appellant claimed interest expenses of $3,840, $4,160, $4,640 and $4,200 for the 1993, 1994, 1995 and 1996 taxation years respectively; (q)         The loan on which the appellant paid interest amounted to $58,500 when the bed and breakfast commenced operations; (r)         From the amount of $58,500, only $22,900 was applied to the mortgage on the residence; the rest was used to repay a line of credit and another loan of the appellant; (s)         The Minister recognized as part of the allowable interest expenses only the interest payable on the portion of the loan used to finance the property less the portion used for personal purposes; (t)          For the 1994 taxation year, the appellant claimed a total of $8,400 as expenses relating to the use of a motor vehicle for the two businesses; (u)         For the 1994 taxation year, an amount of $4,000 in relation to the use of a motor vehicle was allowed by the Minister on the basis of the supporting documents provided by the appellant; (v)         The Minister reduced some of the other expenses claimed by the appellant on the basis of the percentage of personal use of the residence. [4]      The appellant had the burden of proof with respect to each element and he essentially provided general explanations intermingled with irrelevancies. ...

The due diligence was in contacting government authorities on at least two occasions, insisting on written confirmation from the suppliers and relying on what appeared to be the industry practice. [7]      In connection with the Appellant's position that it should be entitled to ITCs, the Appellant argues that to deny the credit is a denial of the very structure and object of the GST legislation. ...

However, the evidence adduced does not allow us to make a connection between Exhibit A-7 and Exhibit A-1, the receipts for interest paid. ...

There is a connection between the two orders which is contemplated in the wording of the second order. ...

Canada, [2] Respondent's counsel suggested that the onslaught of MS was not a lack of normal physical development. [18]     In connection with the issue of incremental costs to enable access, mobility, or functionality, Crown counsel argued that the requirement the costs be incremental meant that they must pertain to Mr. ...

In this connection reference is made to the following exchange which happened to occur in the course of the submissions.... ...

Quaidoo's venture, being his family connection in Ghana, which, based on the Stewart, [1] Walls [2] and Moldowan [3] cases, required an analysis of the following factors to determine if Mr. ...

The cottage was moved in order to lay foundations that would ultimately make it possible to build a habitable basement. [4]      During the excavation and foundation construction, the cottage was moved from its original location and serviced by means of temporary facilities and connections; the appellants continued to enjoy the premises. [5]      For this phase of the work, the appellants spent approximately $28,000 on various contracts. ...