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TCC

Lewisporte Holdings Ltd. v. R., [1999] 1 CTC 2056, 99 DTC 253, 1998 CanLII 185

There is a direct connection between the money borrowed from the Bank and immediately paid back to the Bank to pay off the guarantee. ...
TCC

Dupriez v. R, [1999] 1 CTC 2227, 98 DTC 1790

In this connection counsel relied on s. 118.1(1) and s. 118.1(2) of the Act and ss. 3500 and 3501 of the Income Tax Regulations (“the Regulations”). ...
TCC

Lanctot v. R.|, [1999] 1 CTC 2463, 98 DTC 1475

In connection with Mr. Lanctôt’s practice of dentistry, it should be noted that he sold his own clinic in 1987 and that from that year onward he paid the rental and administrative costs by giving up 40 percent of his fees to the clinic where he worked. ...
TCC

Hansen v. R., [1998] 4 CTC 2412, 98 DTC 2112

That the Plaintiffs are entitled to be indemnified by Westminer against all costs, charges and expenses reasonably incurred, and to be incurred in connection with the Ontario Action. ...
TCC

Whalen v. R., [1999] 4 CTC 2109 (Informal Procedure)

In connection with this argument, Mr. Kenny submits that the R.C.M.P. is, in effect, a third party and that the actual employer was the Treasury Board and consequently, section 231 is applicable. ...
TCC

Apte v. R., [1999] 4 CTC 2145 (Informal Procedure)

In the fall of 1990, the Appellant was approached by a corporation in Edmonton, specifically, the Sherritt Corporation, and offered a position in that city in connection with his scientific background. ...
TCC

Groupe Immobilier Grilli inc. v. The Queen, 2019 TCC 223

Canada, 99 DTC 5117 (para. 21), “a deduction cannot be so far removed from its corresponding income stream as to render its connection to the anticipated income tenuous at best.” ...
T Rev B decision

Regin Properties Limited v. Minister of National Revenue, [1979] CTC 2149, 79 DTC 156

In this connection, the decision of Mr Justice Addy in Roy M Power v Her Majesty the Queen, [1975] CTC 580, 75 DTC 5388, should be borne in mind. ...
T Rev B decision

Gabriel Dubé, Georgette Dubé, Rene Dube v. Minister of National Revenue, [1979] CTC 2241, 79 DTC 10

The appellant company was entitled to deduct the expenses in question except those that were incurred in connection with replacing the boilers. ...
T Rev B decision

Les Immeubles Réal Verreault Ltée v. Minister of National Revenue, [1979] CTC 2583, 79 DTC 455

It is apparent from the portion of his judgment in the Soalta case dealing with the “Edmonton property”, at p 5365, that Mr Justice Cattanach was very much aware that the obvious conclusion to be drawn from the bare fact of the grant of an option is susceptible of considerable modification by evidence of the circumstances in which it was granted, although he did not find it necessary to say so in connection with the “6th St Calgary” transaction. ...

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