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TCC

S.T.B. Holdings Ltd. v. The Queen, 2011 DTC 1118 [at at 650], 2011 TCC 144, aff'd 2002 DTC 7450, 2002 FCA 386

A copy of the caveat forbidding registration filed by STB in connection with its option related to the Khullar Property (described in paragraph 53 above) and the accompanying Certificate of Title was produced.     58. ... Earlier in the Bulletin it is stated that "the fact that the business operations of a taxpayer are of different natures, for example manufacturing and selling, does not preclude them from being the same business" if there is some connection, interlacing or dependence between the activities ...
TCC

Gagnon v. The Queen, 2011 DTC 1030 [at at 128], 2010 TCC 482

They import such meanings as "in relation to", "with reference to" or "in connection with". The phrase "in respect of" is probably the widest of any expression intended to convey some connection between two related subject matters.   46      In my view, this is enough to dispose of the second point. ...
TCC

Radage v. The Queen, 96 DTC 1615, [1996] 3 CTC 2510 (TCC) (Informal Procedure)

In The Oxford Companion to Philosophy, under “Thinking”, the following appears: In its diverse forms — as reasoning, believing, reflecting, calculating, deliberating- thinking appears to enjoy an intimate connection with speech, but just what that connection might be is difficult to establish. ...
TCC

Royal Bank of Canada v. The Queen, [2007] GSTC 122, 2007 TCC 281

  [9]      At the outset, each party bore its own costs and expenses in connection with their respective roles under the program. More specifically, section 1 of Schedule “H” of the Agreement provided that CAIL was to pay all costs and expenses incurred in connection with issuing Points. ...
TCC

Hedges v. The Queen, 2014 TCC 270, aff'd 2016 FCA 19

I intend to interpret the words of Schedule VI-I-2(d) of the Act as written, and I interpret them as saying, in connection with dried marihuana: dried marihuana is zero-rated unless dried marihuana may, under the MMARs, be sold to a consumer without a prescription or exemption. ... The requirement under section 6(c) of the MMARs, in connection with the completion of the medical declaration, is simply that the practitioner indicate “for the purposes of determining under subsection 11(3), the maximum quantity of dried marihuana to be authorized, the daily amount of dried marihuana, in grams, and the form and route of administration that the applicant intends to use.” ...
TCC

Lupien v. The Queen, 2016 TCC 2

It is the benefit and advantage of the good name, reputation, and connection of a business. ... Goulet’s task was [translation] “to estimate the fair market value of the portion of goodwill paid by Chemcraft Sadolin inc. on July 31, 2002, which was attributable to [LCR’s] activities”. [18] Although there is a connection, that was not directly the issue to be determined in this dispute. ...
TCC

Edison Transportation, LLC v. The Queen, 2016 TCC 80

Anthony Vitrano (“Vitrano”), a Florida resident was the sole shareholder of Gameday Connection, Inc. ... When one considers Hill’s testimony that he expressed concerns funds being transferred to iTransit might affect the ability of the Appellant to conduct its contracted obligations, it seems clear there was no connection between these payments and invoices. ...
TCC

Germain Pelletier Ltée v. The Queen, docket 96-3585-IT-G

These appeals raise a number of issues, including: (i) as regards the 1990 taxation year, whether GPL incurred a $259,776 business investment loss in connection with a bad debt; (ii) as regards the 1991 taxation year, whether GPL incurred a $646,487 capital loss in connection with certain investments (advances and shares); (iii) as regards the 1992 taxation year, whether GPL owes interest and penalties on deficient tax instalments; and (iv) as regards the assessment of June 2, 1995, under section 160 of the Act, the fair market value of the property (Montbeillard land) transferred by SIM to GPL on August 8, 1991 (appraisal date) and the amount of SIM’s tax liability. [2] On the last point, the Minister argued that the fair market value of the land was $5,700,000, while GPL argued that the land was worth $4,035,000. ...
TCC

Caraberis v. The Queen, docket 95-3085-IT-G

Thus, all advances received from Seagull Pewter and Jonathan Bond were repaid within one year from the end of the taxation year of each corporation in which such advances were received. [11] The Appellants argue that the right of setoff arises when there is a mutuality of parties and a connection between the claims made by each. [2] This right was described by Middleton J. as follows: [3] There is, however, another equity which has sometimes been called ‘set-off’ but which does not in any way depend upon the statute, which arises when the claims are upon the same contract or are so interwoven by the dealings between the parties that the Court can find there has been established a mutual credit, or an agreement, express or implied, that the claims should be set one against the other. ... Without such connection, an equity to set-off will not necessarily be granted, an intention to liquidate a debt by the other would have to be found (see s. 130, Canadian Encyclopaedic Digest (Western) 3rd edition, Debtor and Creditor). ...
TCC

Spruce Credit Union v. The Queen, 2012 TCC 357

This is less than a strong nexus but more than a mere possibility or a connection with an extreme degree of remoteness. ...   [74]         The phrase “in contemplation of” in subsection 248(10) allows either prospective or retrospective connection of a related transaction to a common law series. ...

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