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T Rev B decision

A Godfrey Harvey v. Minister of National Revenue, [1980] CTC 2129, [1980] DTC 1094

On another occasion H’Oseason informed me that through his wife’s connections in mainland China (his wife is Chinese) he was sure he would be able to arrange for me to be appointed Chinese Consul in Vancouver. ...
TCC

Walter Polhill v. Minister of National Revenue, [1984] CTC 2911, [1984] DTC 1735

“Personal or living expenses’’ is defined as follows: 248. (1) In this Act, “personal or living expenses’’ includes (a) the expenses of properties maintained by any person for the use or benefit of the taxpayer or any person connected with the taxpayer by blood relationship, marriage or adoption, and not maintained in connection with a business carried on for profit or with a reasonable expectation of profit, 18. (1) In computing the income... ...
TCC

Easton (R.) v. Canada, [1994] 1 CTC 2609

The appellant's submission In relation to the yacht charter expenses, at all material times the appellant submits that the losses and expenditures incurred by the appellant in connection with the yacht chartering operation were made or incurred for the purpose of gaining or producing income from a business or property within the meaning of paragraph 18(1)(a) of the Income Tax Act, R.S.C. 1952, c. 148 (am. ...
FCA

Lachance (J.M.A.) v. Canada, [1994] 2 CTC 185

The purpose of subsection 96(1.1) is clearly not to determine how to calculate the income or loss of a retiring partner in connection with his assessment for a taxation year, taking into account the allowance resulting from the agreement n question, but simply to create a fiction which only applies for the purposes of subsection (1) and sections 101 and 103 of the Act.... ...
TCC

Ferme Klosterhos Inc. v. Her Majesty the Queen Rony Scherer v. Her Majesty the Queen Elizabeth Scherer v. Her Majesty the Queen, [1996] 1 CTC 2934

Gagnon concluded that there could be a connection between the cash payments and the advances given to Klosterhos, even though this reconciliation did not produce an exact correspondence. ...
TCC

Anderson v. The King, 2024 TCC 72 (Informal Procedure)

The Minister has not specifically addressed the second notice of objection of June 12, 2023 made in connection with the refusal of March 15, 2023. [32] The Appellant argues that it was filed within 90 days. ...
EC decision

Allan Morrison v. Minister of National. Revenue, [1917-27] CTC 343, [1920-1940] DTC 113

He was assessed to income-tax under Schedule D on his profits on the sale of the linen, and on appeal to the Special Commissioners he contended that he did not carry on any trade in connexion with linen, that the transaction was an isolated one, and that the profit was not an annual profit chargeable to income-tax. ...
BCCA decision

M. D. Donald Limited v. Charles R. Brown, [1928-34] CTC 147

., p. 7, where the learned authors say: "‘‘In connection with corporations and joint-stock companies, it is a cardinal distinction that the incorporated body is a totally different person or entity from the individuals comprising it, even if an individual holds the whole of the shares of the corporation’, and cites John Foster & Sons v. ...
EC decision

His Majesty the King v. Consolidated Lithographing Manufacturing Company Limited, Defendent., [1928-34] CTC 227, [1920-1940] DTC 254

It would have been easy for the legislators, had they wished to include in the sale price the excise tax, to have said so specifically as they did in connection with the excise duties. ...
SCC

City of Toronto v. Ontario Jockey Club, [1928-34] CTC 245

It is clear that the question of whether or not a corporation is liable for business assessment in connection with the lands occupied by it, upon which its affairs are carried on, does not depend on whether or not a profit is being made. ...

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