Search - connection
Results 5001 - 5010 of 6336 for connection
BCCA decision
Attorney-General of Canada, Attorneygeneral of British Columbia and Canadian Pacific Railway Company v. City of Vancouver, [1943] CTC 74
In examining the Vancouver Incorporation Act to see what type of taxation it authorizes, we should recall that municipal taxation in connexion with land involves two processes: first an assessment is made, and then a rate is imposed. ... Reference may be made first to s. 46 in connection with which it is submitted by counsel on behalf of the appellant that the words “registered owner thereof” in s. 40(1) (d) do not mean the registered owner of the improvements referred to in section 40(1) (c) but the registered owner of the "‘rateable parcel of land” referred to in section 40(1) (a). ...
EC decision
Frank C. Bower v. The Minister of National Revenue, [1949] CTC 77
(i) There was no advertising, even outside the premises; (ii) he had the appropriate waiting room and two consulting rooms; (iii) no prices were mentioned in connection with the seven or eight types of frame exhibited in his little windows for the observation of patients; (iv) he carried out the functions of examining and testing eyesight and prescribing the suitable glasses—in itself a process calling for much skill and experience —and assembling them in their frames, for example, at the appropriate angle, which, of course, is essential; (v) his net earnings, whatever they were called, were very substantial, particularly in relation to the expenditure on material, that is, on what would be called the stock-in-trade of a business; and, finally, (vi) the proportion between those earnings and the item for stock-in-trade, so called in the account, was very large in relation to the stock-in-trade—far larger than it would normally be in any trading business. ‘ ‘ The observations of Du Parca, L.J., on the subject are also very useful. ... The appellant’s activities in connection with a person’s coming to his office were described by him in detail. ...
SCC
J. R. Moodie Company Limited v. Minister of National Revenue, [1950] CTC 61
It is apparent from the analysis of Exhibit S.3, that: (1) On the execution of the Deed the Donor, in specific terms, “completely and irrevocably’’ divested himself of the ownership of the securities. (2) The Donor did not reserve to himself, in whole or in part, the control or administration of the Trust Property or any part thereof. (3) There is no provision comparable to the one mentioned above in connection with the Bourque case. (4) The only contingency in which the Donor might have derived any benefit from the property would have been the case of the predecease of his daughter without issue and without leaving any relevant testamentary direction; in which event he would have received a share as one of her legal heirs. ... In this connection, reference may be made to article 818 C.C., which reads as follows: " " Fathers and mothers, and other ascendants, relations in general, and even strangers, may, in a contract of marriage, give to the future consorts or to one of them, or to the children to be born of their marriage, even with substitution, the whole or a portion of their present property, or of the property they may leave at their death, or of both together.” (2) The Donor, intervening in the Marriage Contract, "‘makes a gift to his daughter in advancement of her share in his succession and to any child or children who may be born of her the future wife accepting thereof for herself and them of the sum of TWENTY-FIVE THOUSAND DOLLARS which he promises and obliges himself forthwith to pay to the Trustee hereinafter named to be held by it the said Trustee and its successors in the Trust for the following purposes: The payment so to be made may be made either in money or in securities the securities and the value thereof to be designated by the said Donor. ’ ‘ It is admitted by the parties that securities to the amount of the gift were actually delivered to the Trustee partly on the 26th and partly on the 28th December, 1928. (3) The "purposes’’ are enumerated in clauses numbered (1) to (3) in the intervention. ...
TCC
Matte v. The King, 2025 TCC 16
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. [61] [34] Pursuant to subsection 6(15) of the ITA, it is only when an employee debt is forgiven by an employer that, for the purpose of paragraph 6(1)(a), a benefit shall be deemed to have been enjoyed by the employee at any time an obligation issued by any debtor is settled or extinguished. ...
TCC
Bérubé v. The King, 2023 TCC 12, aff'd 2025 CAF 112
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. ...
TCC
D'Auteuil v. The King, 2023 TCC 3, aff'd 2025 CAF 112
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
Alberta Power (2000) Ltd. v. The Queen, 2009 DTC 1514, 2009 TCC 412
… 4 The balancing pool administrator shall carry out the following powers and duties in accordance with the Act, the regulations and the rules of the balancing pool; (a) sign contracts, agreements and other instruments in respect of the balancing pool; (b) make and maintain banking arrangements in respect of the balancing pool; (c) borrow money from any person or enter into overdraft or line of credit arrangements with a bank, treasury branch, credit union, loan corporation or trust corporation for the purpose of meeting obligations of the balancing pool as they become due, and give security for the loan, overdraft or line of credit; (d) draw, make, accept, endorse, execute or issue promissory notes, bills of exchange or other negotiable instruments in respect of the balancing pool; (e) hire employees, consultants and advisors required in connection with the administration of the balancing pool and the performance of the powers and duties of the Council and the balancing pool administrator and determine the duties, terms of engagement and remuneration of the employees, consultants and advisors; (f) determine the amount of any obligation or expenditure payable out of the balancing pool under section 7(1)(h); (g) carry out any other duties that are necessary to administer the balancing pool. 5(1) The balancing pool administrator shall carry out the following powers and duties in accordance with the Act, the regulations, the rules of the balancing pool and any arrangement: (a) oversee the payment into the balancing pool of the amounts referred to in section 6; (b) oversee the payment out of the balancing pool of the amounts referred to in section 7; (c) determine the amounts of any balancing pool credits and balancing pool charges; (d) allocate balancing pool credits directly to customers or indirectly to customers through (i)retailers (ii)wire service providers, (iii) the power pool administrator; (e) levy balancing pool charges directly against customers or against customers through (i)retailers (ii)wire service providers, (iii) the power pool administrator; (f) offer for sale to the public an arrangement held by the balancing pool administrator as a party to the arrangement; (g) offer for sale to the public any derivatives created by the balancing pool administrator pursuant to the Power Purchase Arrangements Regulation (AR 170/99); (h) exercise any powers and perform any duties that accrue to the balancing pool administrator as a party to an arrangement or to the balancing pool under an arrangement; (i) exercise or assign to a third party the right to exchange electric energy through the power pool that arises as a result of the balancing pool administrator being a party to an arrangement; (j) on receipt of notice in respect of an extraordinary event from a party to an arrangement or otherwise, assess and verify the occurrence of the extraordinary event and the need for any payment to be made into or out of the balancing pool by or to a party under the provisions of the arrangement, and participate in any dispute resolution proceedings under an arrangement pursuant to subsection (3); (k) where clause (j) applies, commence making payments set out in the arrangement until the matters in question under clause (j) have been resolved, whether by agreement or in dispute resolution proceedings under subsection (3); (l) make, defend, settle and withdraw claims and counterclaims against the balancing pool relating to an arrangement that the balancing pool administrator holds as a party to the arrangement; (m) make, defend, settle and withdraw claims and counterclaims against retailers, wire service providers, customers and any other persons relating to the payment of balancing pool credits or charge. …. 6 The following amounts must be paid into the balancing pool (a) any payment, fee, charge or other amount that is required by the Act or the regulations to be paid into the balancing pool; (b) any payment, fee, charge or other amount that is required by an arrangement to be paid into the balancing pool, including any payment that is required to be made as a result of the occurrence of an extraordinary event or as the result of the resolution of a dispute referred to in section 5(3); (c) any balancing pool charge payable, directly or indirectly, by a customer pursuant to billing; (d) any money borrowed for the purpose of meeting the obligations of the balancing pool; (e) any principal, income, dividend or other amount received in connection with investments made pursuant to section 8; (f) any amount received by the balancing pool administrator in respect of an arrangement held by the balancing pool administrator as a party to the arrangement; (g) any fine imposed by the Council in accordance with section 9.5(1)(c) of the Act; (h) any amount approved by the Board as payable into the balancing pool for any period prior to an arrangement taking effect; (i) any other amount received in the course of the administration of the balancing pool, except an amount that is specified by the Minister as not being payable into the balancing pool. 7(1) The following amounts must be paid out of the balancing pool: (a) any payment, fee, charge or other amount that is required by the Act or the regulations to be paid out of the balancing pool; (b) any payment, fee, charge or other amount that is required by an arrangement to be paid out of the balancing pool, including any payment that is required to be made as a result of the occurrence of an extraordinary event or as the result of the resolution of a dispute referred to in section 5(3); (c) any balancing pool credit owing, directly or indirectly, to a customer pursuant to billing. (d) any principal or interest to be paid or repaid in connection with an amount borrowed for the purpose of meeting the obligations of the balancing pool; (e) money payable as the purchase price for investments made pursuant to section 8; (f) any amount payable by the balancing pool administrator in respect of an arrangement held by the balancing pool administrator as a party to the arrangement; (g) any amount approved by the Board as payable out of the balancing pool for any period prior to an arrangement taking effect; (h) any other obligation or expenditure incurred in the course of the administration of the balancing pool, except those that are specified by the Minister as not being payable out of the balancing pool ... To execute the following described agreements in connection with H.R. ...
TCC
RCI Environnement Inc.(Centres de Transbordement et de Valorisation Nord-Sud Inc.) v. The Queen, 2008 DTC 4982, 2007 TCC 647, aff'd , 2009 DTC 5940, 2008 FCA 419
On October 16, 1998, and November 12, 1998, two more statements of account were issued by Langlois Gaudreau to RCI, in connection with the non-competition clauses (I-3, tab 9). 29. ... When the words “permanent” or “enduring” are used in this connection it is not meant that the advantage which will be obtained will last forever. ... Given the conclusion I have reached, it is not necessary to dispose of this question. [22] The non-solicitation agreement was not entered in evidence, but there is no reason to believe that it is not also governed by the laws of Quebec, since all of the agreements in connection with the sale of WMI's Quebec business to RCI and CTVNS are. [23] According to Le Petit Robert, in the definition of " droit ": "[TRANSLATION] I• A right, rights... 2• Real rights, which may be set up against everyone and enable the holder to exercise a power over property (ownership, usufruct, use, etc.). ...
TCC
Brasserie Futuriste de Laval Inc. c. La Reine, 2006 TCC 503
In early December, she received the first daily reports prepared by employees in connection with the sale of alcoholic beverages over the course of approximately four weeks (Exhibit I‑9). ... Morand faced in connection with alcoholic beverage sales was different because, after making her second request to Michel Légaré, she finally obtained close to three months' worth of daily reports filled out by the employees, that is to say, the reports filled out from November 7, 1998, to January 31, 1999. ... Richard in connection with the Appellant's sales. [138] The Appellant's expert Marc Bélanger admitted that, apart from the unreported and unremitted GST, the Appellant owed an additional $14,542 in GST on unreported sales that he estimated at $389,473 (Exhibit A‑28, at pages 6 and 7). ...
SCC
Forbes v. The Attorney General of Manitoba / Worthington v. The Attorney General of Manitoba, [1936] SCR 40
Attorney-General for British Columbia [20], the Judicial Committee, dealing with the statutory stipulation of a timber licence under the British Columbia Crown Lands Act, which provided that this licence is issued and accepted on the understanding that no Chinese or Japanese shall be employed in connection therewith, held that, by reason of the Japanese Treaty Act, 1913, enacted by the Dominion Parliament, the stipulation as regards Japanese was void; but that it must prevail as regards the employment of Chinese. ... No deputy head, officer, clerk or employee in the civil service shall be debarred from voting at any Dominion or provincial election if, under the laws governing the said election, he has the right to vote; but no such deputy head, officer, clerk or employee shall engage in partisan work in connection with any such election, or contribute, receive or in any way deal with any money for any party funds. 2. ... Read in connection with the language of s. 3, as they are expressly required to be by the words of reference above quoted from that section, they are the vital provisions which specifically indicate the real incidence and effect of the tax, fixing not only the time or times at which the tax shall be paid and the manner in which it shall be levied and collected, but the particular moneys upon and from and out of which it shall be levied, deducted and paid, and the person (the employer) who shall so levy and deduct it and ultimately pay it to the income tax administrator. ...