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TCC

Halifax Green Elevator Ltd. v. The Queen, 96 D.T.C 1178, [1996] 1 CTC 2955 (TCC)

The expert business skills, connections and profile of the persons involved at CMM were evident. ... Even if that were not the case, CMM had an enforceable legal right, reflected in tabs 19, 20, and 21 of Exhibit A-l, to call upon its major shareholders for up to $3,000,000 in connection with its guaranteed commitment to the Halifax Port Corporation. ...
TCC

Advanced Agricultural Testing Inc. v. The Queen, 2009 DTC 687, 2009 TCC 190

If, for example, the same vehicle was used in the yard to perform functions in connection with maintenance and several trials that were being conducted concurrently, then the cost of operating that vehicle, including the fuel used in it, would properly be considered overhead. ... Nor is it necessary to do so, as it appears from the appellant’s reply to the respondent’s written argument that the issue only arises in connection with trials #48, #49 and #50, which I have found do not qualify as SRED ...
TCC

Alexandroff v. The Queen, 95 DTC 767, [1995] 1 CTC 2434 (TCC)

., or any affiliate or subsidiary designated by it, whereby it will, because of its knowledge of the property, have the right to act as leasing agent, and when applicable, as sales agent for the limited partnership and to have any listing, whether for lease or sale, in connection therewith, in the event of leasing of available space or any sale of the Swansea Shopping Centre Project comprising the business of the limited partnership and shall be entitled to payment in the amount and on the terms usually paid to independent leasing or sales agents operating in the city of Toronto performing similar functions. 10.01 Each subscribing limited partner shall provide by way of initial capital contribution, for each unit acquired, the sum of $100,000, the sum of $12,500 which was delivered at the time of delivery of the subscription and the balance by cash or certified cheque on or before April 15, 1986. 10.02 Each subscribing limited partner shall further provide by way of capital contribution, for each unit acquired, the further sum of $100,000 such amount to be paid by way of delivery of a promissory note issued in favour of H.L. ... We request that our concerns are passed on as soon as possible to those responsible for the excavation and that Consumers’ Gas be notified so that they can inspect the connection. ...
ABDC decision

R. v. Myers, 77 DTC 5278, [1977] CTC 507 (Alta. Dist. Ct.)

Accordingly, it applies only to those provisions of the Act which relate to the specific term ‘tax payable by a taxpayer’’, or to ‘tax payable’’, in connection with the assessment of income tax. ... Again in 1971, the Department’s calculation allowed $1,797.92 as postage expense in connection with silver sales but included no income from the sale of silver in that year for lack of any other evidence thereof. ...
TCC

Osfc Holdings Ltd. v. R., 99 DTC 1044, [1999] FTR 33266, [1999] 3 CTC 2649, aff'd 2001 DTC 5471, 2001 FCA 260

Other issues in connection with the terms of the original Partnership Agreement arose too, and so the Agreement of Purchase and Sale had annexed to it an Amended and Restated Partnership Agreement to be executed by the original partners prior to closing. ... , [17] Strayer J.A., the context of subsection 15(1.1) of the Act, said: In this connection we refer to the decision of this Court in H.M. v. ...
FCA

Canada v. Harris, 2000 DTC 6373 (FCA)

In Canada that confidentiality is required, in circumstances such as the present, by section 241(2) of the Income Tax Act which states that no official shall be required in connection with any legal proceedings to testify as to information obtained on behalf of the Minister for the purposes of the Act. ... _to any person any taxpayer information," and that "no official shall be required, in connection with any legal proceedings, to give or produce evidence relating to any taxpayer information. ...
TCC

Brillon v. The Queen, 2008 DTC 3445, 2006 TCC 76 (Informal Procedure)

Such activities have absolutely no connection with the subject of the DAMDES project and make no contribution to the work done by several academics recruited for the project, who are very familiar with the technologies underlying the software examined in the feasibility study. ... Consequently, the following changes will be made in calculating your tax payable for 1989 and any other year that may be concerned:  -          the tax credit earned in connection with your interest in the partnership is refused;-          the business loss from this partnership, which you deducted, represents investment expenses that must be included in calculating the cumulative net investment loss. ...
TCC

Hill v. The Queen, 2002 DTC 1749 (TCC)

The Appellant also argued that the Respondent had admitted both in the Reply and in the Agreed Statement of Facts that the excess amounts were payable. [9]            In connection with the contention that the interest payment was contingent, the Appellant relied on Justice Sharlow's comments in Wawang Forest Products Ltd. v. ... RESPONDENT'S SUBMISSIONS: [28]          Similarly, the Respondent acknowledged that the argument in connection with GAAR can be limited to a "misuse and abuse" analysis. ...
FCA

The Queen v. Graham, 85 DTC 5256, [1985] 1 CTC 380 (FCA)

See also s 139(l)(ae) of the Income Tax Act which includes as “personal and living expenses” and therefore not deductible for tax purposes, the expenses of properties maintained by the taxpayer for his own use and benefit, and not maintained in connection with a business carried on for profit or with a reasonable expectation of profit. ... —“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, On the basis of the principle established by section 3 of the Act, therefore, people involved in farming activities should normally come into two groups only: those for whom farming is not a business but a hobby, who do not expect profit from their farming activities and whose expenses in farming must simply be treated as non-deductible “personal or living expenses” and the others whose loss sustained in carrying on their farming activities would be deductible from their total income as any other business loss. ...
TCC

Byrt v. MNR, 91 DTC 923, [1991] 2 CTC 2174 (TCC)

There must be a rational connection between the basic fact of possession and the presumed fact of possession for the purpose of trafficking. ... There is a rational connection between the fact of being a director and the failure of the corporation to withhold and pay taxes. ...

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