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Results 4851 - 4860 of 6326 for connection
SCC
His Majesty the King v. Noxzema Chemical Company of Canada, Limited, [1942] CTC 21, [1941-1946] DTC 542
That organization had no connection whatever with Bromo Seltzer Limited but was a company engaged in marketing different products. ...
EC decision
His Majesty the King on the Information of the Attorney-General of Canada v. Toronto General Trusts Corporation,, [1942] CTC 65
In this connection he referred to the case of Cross v. London & Provincial Trust Ltd., [1938] All E.R. 428, where the Brazilian Government having suspended interest payments upon certain bonds had issued funding bonds in lieu of unpaid interest to bond holders and it was held that the issue of the funding bonds was the issue of a capital asset and not a payment of interest and therefore not taxable. ...
ONCA decision
Montreal Trust Company v. City of Toronto, [1944] CTC 48
Miller, 22 D.L.R. 75, [1915] A.C. 318, in connection with the law as to the registration of titles in the Province of British Columbia, and came to the conclusion that though the purchaser of real estate might, before conveyance, have an equitable interest capable of registration, such interest was in every case commensurate only with what would be decreed to him by a Court of equity in specifically performing the contract, and could only be defined by reference to the relief which the Court would give by way of specific performance.” ...
EC decision
Wrights’ Canadian Ropes Limited v. Minister of National Revenue, [1945] CTC 177, [1941-1946] DTC 712
In computing the amount of the profits or gains to be assessed, a deduction shall not be allowed in respect of... (1) Any sums charged by any company or organization outside of Canada to a Canadian company, branch or organization, in respect of management fees or services or for the right to use patents, processes or formulae presently known or yet to be discovered, or in connection with the letting or leasing of anything used in Canada, irrespective of whether a price or charge is agreed upon or otherwise; but only if the company or organization to which such sums are payable, or the company in Canada, is controlled directly or indirectly by any company or group of companies or persons within or without Canada, which are affiliated one with the other by the holding of shares or by agreements or otherwise; provided that a portion of any such charges may be allowed as a deduction if the Minister is satisfied that such charges are reasonable for services actually rendered or for the use of anything actually used in Canada. 2. ...
EC decision
James C. Mahaffy v. Minister of National Revenue, [1945] CTC 408
It must be read in connection with other sections, including section 5.1(f) and 6.1(a), but as I have found that the appellant cannot succeed under these sections and as I have not been referred to any other section where such an allowance could be made, I must conclude that the appellant must fail under the provisions of this subsection. ...
EC decision
George Frederick Daniels Bond v. The Minister of National Revenue, [1946] CTC 281
The disbursements that must be made to earn profit are those in connection with unascertained incomes, unlike a case of salary, where disbursements are made at the discretion and the will of the taxpayer,—and after all are not these disbursements measured by the hospitable disposition of each Lieutenant-Governor, and are they not freely and voluntarily incurred and so not enforceable by law.’’ “ " What that section means is that in " a trade or commercial or financial or other business or calling before the amount upon which the tax is to be levied is ascertained, the amounts expended to earn the same must be deducted ‘ ‘; and then the dictum follows: "‘But it is otherwise in the case where a person received an annual salary from any office or employment—an amount which is duly ascertained and capable of computation, and which constitutes of itself a net income’’ In Samson v. ...
EC decision
Vancouver Towing Company Limited v. Minister of National Revenue, [1947] CTC 18
I find it impossible to adopt the view that a person who, by having the requisite voting power in a company subject to his will and ordering, can make the ultimate decision as to where and how the business of the company shall be carried on, and who thus has, in fact, control of the company’s affairs, is a person of whom it can be said that he has not in this connection got a controlling interest in the company. ’ ’ Counsel for the appellant in the instant case urged upon me that this portion of the judgment was authority for finding that Jones, in full control of the Vancouver Tug and Barge Co., which in turn had more than a majority of the shares in the appellant company, had, therefore, the controlling interest in the appellant company. ...
EC decision
Robert F. Acorn v. The Minister of National Revenue, [1948] CTC 135
In connection with the rule that words must be construed according to their ordinary and grammatical sense reliance was placed on Beal’s Cardinal Rules of Legal Interpretation, 3rd edition, p. 343, where, under the heading “The Golden Rule”, the author states: Lieutenant’s pay, being $3.60 per day, less tax deducted of 804 $ 56.80 15 days at annual Camp at Captain’s pay, being $5.20 per day 78.00 $134.80 5. ...
EC decision
Orrin H. E. Might, v. The Minister of National Revenue, [1948] CTC 144
The intention of Parliament must be gathered from the language employed, having regard to the context in connection with which it is used. ...
PC decision
D. R. Fraser & Company Limited v. Minister of National Revenue, [1948] CTC 297
It was argued that the Minister in originally intimating his decision had in effect stated that he based it on the ground that the appellant company as licensees were not as such entitled under the Statute to any allowance for depletion of timber limits which belonged to the Crown, and in this connection reference was made to the evidence of Mr. ...