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Results 4981 - 4990 of 6326 for connection
FCTD
Lawrence H Mandel/ v. Her Majesty the Queen, [1976] CTC 545, 76 DTC 6316
An agreement dated February 1, 1973 between Canadian Film Development Corporation, Amaho Limited referred to as the assignee, Topaz Productions Limited, Niagara Television Limited, Robert Lawrence Productions Limited, John T Ross, and One Flag Under Ontario Investments Limited & Film Associates and Alexis Kanner, sets out that Niagara provided financing of the film in the amount of $125,000 and paid a further sum of approximately $10,000 in connection with the completion of it. ... Lord Reid stated at page 858: No doubt the words “liability” and “contingent liability” are more often used in connexion with obligations arising from contract than with statutory obligations. ...
TCC
Alexander v. The King, 2022 TCC 147
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. [42] According to the Brandon Affidavit, on January 15, 2016, the Respondent sent to the Appellant a copy of a 2016 CRA position paper prepared by the auditors responsible for the audit of the Program and the audit reports of the Appellant dated June 21, 2004 and July 11, 2005. ...
T Rev B decision
Rev John K Hofer, Rev Peter S Tschetter, Jacob K Wipf, Rev Joseph K Wipf and Rev John K Wurz v. Minister of National Revenue, [1972] CTC 2275, 72 DTC 1248
The objects of the Corporation shall be to engage in and carry on the Christian Religion, Christian worship and religious education and teaching and to worship God according to the religious belief of the members of the Corporation. 7. (1) The Corporation may purchase, take, have, hold, receive, possess, retain and enjoy property, real or personal, corporeal or incorporeal, and any or every estate or interest whatsoever given, granted, devised or bequeathed to it, or appropriated, purchased or acquired by it in any manner or way whatsoever, to, for, or in favour of the uses and purposes of the Corporation or to, for, or in favour of any religious, educational, eleemosynary or other institution established or intended to be established by, under the management of, or in connection with, the uses or purposes of the Corporation. 8. ... To Carry on any other business (whether manufacturing or otherwise) which may seem to said congregation or community of the said Church capable of being conveniently carried on in connection with its business or calculated directly or indirectly to enhance the property or rights of the congregation or community; iii. ...
T Rev B decision
Marcel, Rene and Yvonne Giguere v. Minister of National Revenue, [1972] CTC 2466, 72 DTC 1392
This direction proceeds from a laborious inquiry and this is what prompted the departmental direction: It is recommended that directions under Section 138A(1) be made against the above-noted persons (Estate of Henri Giguere, Yvonne Giguére, Marcel Giguère, René Giguere and Robert Giguere) in connection with the sale to Giguére Automobile (1964) Inc. of their common shares of Giguére Automobile Limitée and Location Laurentienne Inc. ... It is noted in this connection that General Motors does not normally permit the sale of goodwill on the transfer of its franchise and this eliminates the most likely source of a capital gain. ...
EC decision
Brilund Mines Limited v. Minister of National Revenue, [1971] CTC 403, 71 DTC 5218
Between November 18, 1965 and January 5, 1966 Rosenblat had been in Europe in connection with the operation of his regular business, a chemical plant in New York, and, in addition, on his return had been in New York and also in Toronto before January 5, 1966. ... On the settlement, the appellant probably received most of the gains or profits Harbinson made in connection with his dealings in these shares he appropriated from the appellant. ...
EC decision
Minister of National Revenue v. Gunnar Mining Limited, [1970] CTC 152, 70 DTC 6135
It appears to be perfectly sound to state that—“if” the judgment issued by me on September 24, 1963 had gone one step further and had referred the relevant assessments in respect of the appellant’s 1958, 1959 and 1960 taxation years back to the Minister for re-assessment thereby giving him the opportunity of taking into account, as of the said date of September 24, 1963 (that date is important because the ultimate purpose of this motion is to establish the appellant’s right to interest at 6% on the amounts of overpayment of tax totalling the sum of $469,934.67 calculated in accordance with subsections (3) and (3a) of Section 57 of the Act covering interest on overpayments of tax), the capital cost allowance and deferred exploration and development expense which had previously been agreed to between the Minister and the appellant as being the amounts to which the appellant was entitled in respect of the said taxation years—the appellant could then have brought itself within Section 57 (3a) of the Act by pointing to a decision of this Board (a court of record) wherein it was determined that the taxes payable by it in connection with its 1958, 1959 and 1960 taxation years were less than the respective amounts assessed by the relevant assessments under Section 46 of the Act from which an appeal was taken, the Board’s decision making it appear that there had been overpayments of tax for the three taxation years in question. 4. In his above-quoted letter dated November 6, 1968, the Deputy Minister stated that there was no statutory authority to pay any interest (it should be carefully observed that the Act provides for interest at 3% under Section 57(3) on an ordinary overpayment of tax but interest at 6% under Section 57 (3a) where the overpayment is apparent from a decision of the Minister or from one of the three courts mentioned therein) in respect of the tax of $469,934.67 being remitted in connection with the appellant’s 1958, 1959 and 1960 taxation years explaining that Section 57 of the Act was not applicable “because of the time limits”. 5. ...
TCC
D'Auteuil v. The King, 2023 TCC 3
Loss (2) Subject to section 31, a taxpayer's loss for a taxation year from a business or property is the amount of the taxpayer's loss, if any, for the taxation year from that source computed by applying the provisions of this Act respecting computation of income from that source with such modifications as the circumstances require.... 40(2)(f) a taxpayer's gain or loss from the disposition of (i) a chance to win a prize or bet, or (ii) a right to receive an amount as a prize or as winnings on a bet, in connection with a lottery scheme or a pool system of betting referred to in section 205 of the Criminal Code is nil;... 248(1) business includes a profession, calling, trade, manufacture or undertaking of any kind whatever and, except for the purposes of paragraph 18(2)(c), section 54.2, subsection 95(1) and paragraph 110.6(14)(f), an adventure or concern in the nature of trade but does not include an office or employment; (commerce) X. ... The right to receive an amount as winnings on a bet is not earned in connection with a lottery scheme or a pool system of betting referred to in section 205 of the Criminal Code. ...
TCC
Bérubé v. The King, 2023 TCC 12
Loss (2) Subject to section 31, a taxpayer's loss for a taxation year from a business or property is the amount of the taxpayer's loss, if any, for the taxation year from that source computed by applying the provisions of this Act respecting computation of income from that source with such modifications as the circumstances require. (...) 40(2)(f) a taxpayer's gain or loss from the disposition of (i) a chance to win a prize or bet, or (ii) a right to receive an amount as a prize or as winnings on a bet, in connection with a lottery scheme or a pool system of betting referred to in section 205 of the Criminal Code is nil; (...) 248(1) business includes a profession, calling, trade, manufacture or undertaking of any kind whatever and, except for the purposes of paragraph 18(2)(c), section 54.2, subsection 95(1) and paragraph 110.6(14)(f), an adventure or concern in the nature of trade but does not include an office or employment; (commerce) IX. ... The right to receive an amount as winnings on a bet is not earned in connection with a lottery scheme or a pool system of betting referred to in section 205 of the Criminal Code. ...
EC decision
Calona Wines Ltd. v. Deputy Minister of National Revenue for Customs and Excise, [1969] CTC 235, 69 DTC 5190
The general intent of this Agreement is that the Commission itself and at its own expense shall perform or cause to be performed all the work required to change over the Company’s existing generating units and facilities from 25 cycles to 60 cycles and that the Company shall not be put to any expense whatever in connection with the actual change-over operation. ... The appellant did not have to make an expenditure of a single cent on capital account in connection with the change-over and, with exactly the same expenditures on revenue account after the change-over as it was making before, it had exactly the same revenues as it had before, and, in addition, it had a plant that would be a revenue producer to itself after 1971 whereas, before the change-over, it had a plant that would have been practically speaking valueless after 1971. ...
EC decision
Canadian General Electric Co. Ltd. v. Minister of National Revenue, [1959] CTC 350, 59 DTC 1217
In 1951, ne > els 'n connection with these liabilities. The 0 a, other in these circumstances a trader ‘red a debt in foreign currency and throughout the following year, is tax-,x Act by reason of the single fact that.. ... In that connection, reference may also be made to Ken Steeves Sales Ltd. v. ...