Search - connection

Harvey has separately made a claim for an internet connection.   [52]         While I do not accept the figure put forward for home office use by Mr.  ... Harvey’s credibility, my specific view of his credibility in respect of the alleged 2003 trip to Victoria, the lack of any documentation supporting the 2003 and 2004 travel expenses, the lack of any documentary evidence of the existence of the conferences or seminars and the connection between the Toronto stopover and a family vacation, I am not prepared to allow Mr. ...

Invoices/receipts in connection with any asset purchased/disposed; 3.             ... There was no nexus or connection or documentation or otherwise for the $305,000. ...

It is quite clear that marketing campaigns cannot create lasting advantages and must necessarily be recurrent. [43]     In conclusion, regardless of whether the sales outlets were "corporate" stores or franchised stores, the advantage that was sought and could reasonably be obtained was an enduring connection to Rona's business structure. [44]     The fact that Rona acquired an ownership interest in Inovaco's capital stock merely for a short period is not relevant. ... They were losses incurred in connection with a capital venture.... I think it is clear that an expenditure incurred for the purpose of enabling a taxpayer to decide whether a capital asset should be acquired is an outlay or payment on account of capital.... [14] Counsel for the plaintiff relied on the judgments of Noël A.C.J. in Bowater Power Company Limited v. ...

In short, there was no connection between any account receivable and any account paya-’ ble: in the business of the broker they were completely independent of each other. ... To use the words employed by Rowlatt, J in Scales v George Thompson and Company Limited, [1927] 13 TC 83, on the facts of this case there was between the broker’s business and the investments an inter-connection, an interlacing, an interdependence, a unity embracing the investments and the business. ...

I told Pertamina that I knew of potential sources of such funds and I travelled from Indonesia to Calgary and to San Francisco and Houston, for example, in connection with this Project ... I have no doubt that Roth had a considerable accumulation of knowledge as a result of his various business activities and connection with those expenses, which knowledge was of great interest to Pac-Rim LNG Joint Venture, leading ultimately to the sale of the five percent interest in the existing project to Pac-Rim LNG Inc, Bechtel Enterprises International LTD, Phillips Petroleum Canada Ltd and Daewoo Corporation.  ...

The notice in connection with this estate does not assume to designate any particular place as the situs of the monies bequeathed. ... The same result necessarily follows in connection with the death of James Kenneth Raeburn and the appeal should therefore be dismissed with costs. ...

Accountants’ and auditors’ working papers include working papers created by or for an independent auditor or accountant in connection with an audit or review engagement, advice papers, and tax accrual working papers (including those that relate to reserves for current, future, potential or contingent tax liabilities). […] Although not routinely required, officials may request tax accrual working papers. ... This was recognized by the Task Force convened by the CICA in connection with the CRA's review of its policy respecting the disclosure of working papers. ...

Notwithstanding the provisions of paragraph 2: (a)     copyright royalties and other like payments in respect of a deduction of any literary, dramatic, musical or artistic work (but not including royalties in respect of motion picture films and work on film, videotape or other means of reproduction for use in connection with television broadcasting; and (b)     royalties for the use of or the right to use computer software or any patent or for information concerning industrial, commercial or scientific experience (but not including any such information provided in connection with the rental or franchise agreement)          arising in a State and paid to a resident of the other State who is the beneficial owner of the royalties shall be taxable only in that other State ...

Lee admits that the sum of $57,609.86 could be discounted to $35,771 for 1971 service connection. ... Gross Sales 55 lots x 5,400 per lot $297,000.00 Hard Costs Servicing (35% of Gross Sales + $35,771 for cost of connection of $145,721.00 services discounted to 1971 + $6,000 cost of lanes, roadways and road allowance) Soft Costs Carrying charges on land ($100,000 @ 8% for 1 year) $ 8,000.00 Half of servicing costs for 1 year $ 4,620.00 Tax & insurance $ 800.00 Contingency $ 5,940.00 Marketing & Profit Sales Commission (5%) $ 14,850.00 Developer's Profit (10%) $ 29,700.00 Total Expenses $209,631.00 Residual Value to Land $ 87,369.00 Value of Land Dec. 31, 1971 $87,369 x.943396 $ 82,423.56 I therefore conclude that the value of the plaintiff's land on December 31, 1971 is $82,423.56 rounded out to $83,000. ...

Counsel pointed out that it is not necessary that the outlay or expense should have resulted in a particular income, that it be in the year that it was expended or that there be a casual connection between the expenditure and a receipt. ... It is true that the expenditure need not produce a profit but in this case there was no connection between the expenditure in question and the Appellants’ other businesses. ...