Search - connection

It only requires that the U.S. tax be paid in relation to the income which is being computed under the Act or in connection with that income ... The phrase “in respect of” is probably the widest of any expression intended to convey some connection between two related subject matters ...   [56]          As set out above, the phrase “in respect of” is a broad expression intended to convey a connection between two related matters. ...

On the date of a grant, stock options were given to employees to complement cash compensation and other entitlements (e.g., pension, saving plans, etc.) and were in respect of then current service. [28] At the time of a change of control, the “in the money” value of a stock option was a contractual right of the employee in respect of past service, and any payment received to compensate for the “in the money” value of the option was in respect of that past service. [29] the stock options granted by Numac to its employees and surrendered to Numac in connection with the acquisition by Anderson; and the stock options granted by Anderson to its employees and surrendered to Anderson in connection with the acquisition by DAC. [30] b) Based on Mr. ... Other capital expenditures might not have related to any particular asset or perhaps were made in connection with an asset which the taxpayer did not own. ... It seems clear that the cost of property may include brokerage fees, legal fees, commissions and other expenses incurred in connection with the acquisition of the property. ...

Thus, the MIP had to point to an extracontractual fault or breach of contract, compensable damage, and a causal connection between the two. ... To succeed in their actions, they will have to prove fault, damage and a causal connection between the two. ... It is true that the MIP contains few specific allegations concerning the mandates given by Fiducie and their connection with the alleged breaches. ...

BACKGROUND TO THE MOTION [1] At issue in the appeal are disallowed claims for partnership losses and carrying charges claimed by the Appellant in connection with the purchase of a one-half unit in a limited partnership tax shelter: Horseshoe Limited Partnership (“Horseshoe LP”). ... More precisely, questions that constitute a fishing expedition are not proper questions either because they are overly broad and/or an abuse of the discovery process or because they have no connection to the matters in issue in the proceeding, or both ... Semantics may play too significant a role in making this distinction, yet the distinction is real: questions aimed at getting a witness to confirm that certain facts are proof of certain allegations are out; questions arrived at getting the witness to divulge relevant facts in connection with an allegation are in.... ...

(g) for defining and determining earnings, pay periods and the amount of insurable earnings of insured persons and for allocating their earnings to any period of insurable employment; (h) for determining the amount of premiums payable; (i) for prescribing and regulating the manner, conditions and times for paying and recording premiums [...] 108. (1) Le ministre peut, avec l'agrément du gouverneur en conseil, prendre des règlements_: [...] g) concernant la définition et la détermination de la rémunération, de la période de paie et du montant de la rémunération assurable des assurés, et la répartition de la rémunération sur une période d'emploi assurable; h) prévoyant la façon de déterminer le montant des cotisations à payer; i) visant à prescrire et réglementer le mode, les conditions et les dates de paiement et d'enregistrement des cotisations [...]. [23]            With respect to barbering and hairdressing establishments, the applicable regulation is section 8 of the Insurable Earnings and Collection of Premiums Regulations (successor to section 16 of the Unemployment Insurance (Collection of Premiums) Regulations), which reads as follows (emphasis added): 8. (1) Every owner or operator of a barbering or hairdressing establishment shall, for the purpose of maintaining records, calculating insurable earnings and paying the premiums payable on those insurable earnings under the Act and these Regulations, be deemed to be the employer of every person whose employment in connection with the establishment is included in insurable employment under paragraph 6(d) of the Employment Insurance Regulations. 8. (1) Le propriétaire ou l'exploitant d'un salon de barbier ou de coiffure est réputé, aux fins de la tenue des registres, du calcul de la rémunération assurable et du paiement des cotisations exigibles à cet égard aux termes de la Loi et du présent règlement, être l'employeur de toute personne dont l'emploi dans le cadre de cette entreprise est inclus dans les emplois assurables en vertu de l'alinéa 6d) du Règlement sur l'assurance- emploi. (2) Every owner or operator of a barbering or hairdressing establishment who is deemed by subsection (1) to be an employer of a person shall, for each week in which the person is engaged in insurable employment in the establishment, pay and remit to the Receiver General the employee's premiums and the employer's premiums in accordance with the Act and these Regulations. (2) Le propriétaire ou l'exploitant d'un salon de barbier ou de coiffure qui est réputé être l'employeur d'une personne en vertu du paragraphe (1) doit, pour chaque semaine au cours de laquelle la personne exerce un emploi assurable dans le cadre de cette entreprise, payer et verser au receveur général les cotisations ouvrières et les cotisations patronales conformément à la Loi et au présent règlement. (3) Where the owner or operator of a barbering or hairdressing establishment is unable to determine the insurable earnings of a person whose employment in connection with the establishment is included in insurable employment under paragraph 6(d) of the Employment Insurance Regulations, the amount of insurable earnings of the person for each week during that employment shall be deemed, for the purposes of the Act and for the purposes of these Regulations, to be an amount (rounded to the nearest dollar) equal to 1/78 of the maximum yearly insurable earnings, unless the owner or operator of the establishment maintains records that show the number of days on which the person worked in each week, in which case the amount of the person's insurable earnings for that week shall be deemed to be an amount (rounded to the nearest dollar) equal to the lesser of (3) Lorsque le propriétaire ou l'exploitant d'un salon de barbier ou de coiffure est dans l'impossibilité d'établir la rémunération assurable d'une personne dont l'emploi dans le cadre de cette entreprise est inclus dans les emplois assurables en vertu de l'alinéa 6d) du Règlement sur l'assurance-emploi, la rémunération assurable de cette personne pour chaque semaine où elle exerce cet emploi est réputée, pour l'application de la Loi et du présent règlement, être le montant (arrondi à un dollar près) égal à 1/78 du maximum de la rémunération annuelle assurable. ...

Work expended on or in connection with the property realized. If effort is put into bringing the property into a more marketable condition during the ownership of the taxpayer or if special efforts are made to find or attract purchasers (such as the opening of an office or advertising) there is some evidence of dealing in the property. 5. ... Given the incorrect or omitted date of the APS for the property itself, the Court is not prepared to give this assumption weight beyond its single occurrence within the factor. iv) Work expended on or in connection of the property [30] There was no assumption or other evidence concerning work expended. ...

The Ravelston Corporation Limited, Conrad Lord Black Capital Corporation); (iii) related party/conflict considerations under applicable corporate and securities law, including, if necessary, depending on the structure of any transaction, the approval of the transaction solely by the independent directors; (iv) withholding tax issues in connection with any loan arrangement (as Lord Black is not a resident of Canada); (v) the fact that the Inc. ... All fees and expenses incurred by Lord Black in connection with the Quest loan, including the Quest Fees and Expenses and net withholding taxes paid, will be apportioned, and reimbursed to Lord Black, on the basis that the amount advanced by BlackCo to Domgroup bears to the total principal amount of the Quest loan (approximately 63%/38%). ... In this connection, the adjectives that have been heretofore used by courts to characterize the requisite purpose in s. 20(1)(c)(i), such as “ bona fide ”, “ actual ”, “ real ” or “ true ”, are to my mind ultimately useful only when describing whether the transaction at issue was a mere sham or window-dressing designed to obtain the benefit of interest deductibility.   ...

., of petroleum or natural gas on a property, there would have to be at least some connection between that expense and work actually done on the ground. ... [emphasis added; footnotes omitted]                   Of particular relevance to this appeal is the finding that, "as a general rule", there would have to be some connection between that expense and work actually done on the ground for an expense to have been incurred for the purpose of determining, inter alia, the existence of oil or gas. ... In the present case, another Shapco company bought the two notes that Technical had given to Karon in connection with the purchase of Petroseis"s seismic data. ...

The legal fees component of this award ($73,000) represents approximately 73% of the fees incurred by the Plaintiffs in connection with their contempt proceedings against Antonio. ... The legal fees represent 100% of the legal fees incurred by the Plaintiffs in connection with these contempt proceedings against Antonio. ... This is particularly so in the context of contempt proceedings. [23] Moreover, I am satisfied that the fixing of an award of lump sum costs would significantly reduce the time and expense that would be required to prepare, review and make submissions on the type of detailed bill of costs that is required for the purposes of an assessment under Tariff B: Venngo Inc v Concierge Connection Inc., 2017 FCA 96 at para 85, leave to appeal to SCC refused [2017] SCCA No 302; Allergan, at para 22. ...

Work expended on or in connection with the property realized. If effort is put into bringing the property into a more marketable condition during the ownership of the taxpayer or if special efforts are made to find or attract purchasers (such as the opening of an office or advertising) there is some evidence of dealing in the property.          5.      ...