Search - connection

Should any other directions be given by this Court in connection with this appeal? ... SHOULD ANY OTHER DIRECTIONS BE GIVEN BY THIS COURT IN CONNECTION WITH THIS APPEAL? ...

The Queen, the Court considered the following factors in determining whether the sale of real property was income: a)   The nature of the property sold and how the taxpayer used it; b)   The length of the ownership period; c)   The frequency or number of other similar transactions by the taxpayer; d)   The work expended on or in connection with the property; e)   The circumstances giving rise to the sale of the property; and f)   The taxpayer's motive regarding the sale of the property at the time of purchase. [19]   The CRA auditor focused on the second and third factors to justify his findings. ... Work expended on or in connection with the property realized. If effort is put into bringing the property into a more marketable condition during the ownership of the taxpayer or if special efforts are made to find or attract purchasers (such as the opening of an office or advertising) there is some evidence of dealing in the property. 5. ...

The Bank refused to provide information regarding “the name of the holder” of a certain account, one category of information sought by the Minister in connection with the investigation of the named person, and any other information which would confirm the holder’s identity. ... Was the RFI issued for a purpose other than the administration or enforcement of the ITA [74] Zeifmans submits that the requests for information and documents in the RFI are so broad that they have no apparent connection to the CRA’s audit of the Named Persons or any purpose related to the administration or enforcement of the ITA. ...

If there is a causal connection between the expense and the inventory it should be included in the cost of inventory. ... Counsel considered that there was a direct causal connection between the harvesting of the logs and the cost of silviculture, therefore, it was correct to treat the silviculture cost as one related to the inventory of logs harvested and not as a period cost. ...

The context for the purpose of the interpretation of a treaty shall comprise, in addition to the text, including its preamble and annexes: (a) any agreement relating to the treaty which was made between all the parties in connexion with the conclusion of the treaty; (b) any instrument which was made by one or more parties in connexion with the conclusion of the treaty and accepted by the other parties as an instrument related to the treaty. 3. ...

.— Gross income derived by a corporation organized in a foreign country from the international operation of a ship or ships if such foreign country grants an equivalent exemption to corporations organized in the United States. 5 This “effective connection” is established by various factors, one of which, admittedly, is Norsk’s place of management. 6 Since this is a determination of foreign law, it is a finding of fact. ... The reason for which Norsk is liable to tax in the United States is not because its place of management is located in the United States, but because the trade or business it conducts is effectively connected with the United States, that connection being established, amongst various factors, by Norsk’s place of management. ...

(c) “Point of measurement” with respect to: (i) crude oil and crude naphtha means the production tanks, of the Lessee to which any well on the said lands is connected; (ii) absorption gasoline and/or natural gas means the point of connection with the gas gathering system connected to the well. ... (c) “Canadian resource property” of a taxpayer means any property acquired by him after 1971 that is (i) any right, licence or privilege to explore for, drill for or take petroleum, natural gas or related hydrocarbons in Canada, (ii) any right, licence or privilege to (A) store underground petroleum, natural gas or related hydrocarbons in Canada, or (B) prospect, explore, drill or mine for minerals in a mineral resource in Canada, (iii) any oil or gas well in Canada, (iv) any rental or royalty computed by reference to the amount or value of production from an oil or gas well in Canada, (v) any rental or royalty computed by reference to the amount or value of production from a mineral resource in Canada, (vi) any real property in Canada the principal value of which depends upon its mineral resource content (but not including any depreciable property used or to be used in connection with the extraction or removal of minerals therefrom), or (vii) any right to or interest in any property (other than property of a trust) described in any of subparagraphs (i) to (vi) (including a right to receive proceeds of disposition in respect of a disposition thereof); [Emphasis added.] ...

It read: 2. (1) In this Act, and in any regulations made hereunder, unless the context otherwise requires, (r) “personal and living expenses” shall include inter alia — (i) the expenses of properties maintained by any person for the use or benefit of any taxpayer or any person connected with him by blood relationship, marriage or adoption, and not maintained in connection with a business carried on bona fide for a profit and not maintained with a reasonable expectation of a profit. ... Apart from specific legislation in a taxing statute, I know of no law which imposes an obligation upon a lender to demand the payment of interest in connection with a loan granted by the lender to a borrower, and if the lender does not require the payment of interest, the borrower is under no obligation to pay interest. ...

The two parts have no connection with one another. Separate searches and separate premises are involved. ... They pointed to a number of items on the inventory filed as Exhibit 2-2 which, in their submission, bore no connection to a tax violation or were outside the guidelines given. ...

The appellant filed a book of documents as Exhibit A-1 and I refer to Tab 1 thereof which shows the corporate connection and interrelationship of Lehndorff Realty Developments Limited, the Canadian corporation. ... I do not accept the respondent’s contention that the interposition of the appellant which entered into all agreements with Canadian developers whereby it, the appellant, provided the majority of the financing and the developer provided the expertise, does categorize what Mr Gill says:... the Appellant did not lend the money to its subsidiary, the Appellant in those transactions had no direct connection, it was merely a loan from Canada Grund to Morenish and Kashel. ...