Search - connection
Results 61 - 70 of 6336 for connection
FCA
Canada v. Alta Energy Luxembourg S.A.R.L., 2020 FCA 43, aff'd 2021 SCC 49
Justice Woods, as she then was, dismissed these arguments: [380] The Minister also submits that the Treaty exemption was not intended to apply to the Trusts because they had very little connection with Barbados. ... It does not matter that the Trusts have few connections with Barbados. ...
TCC
Bombardier Inc. v. The Queen, 2011 TCC 48
Question 6: Is there a connection between the method of recognizing income associated with long-term contracts and the characterization of the amounts received from customers as advances? ... Question 6: Is there a connection between the method of recognizing income associated with long-term contracts and the characterization of the amounts received from customers as advances? ... In fact, chapter 3400, more specifically at paragraphs 3400.06 to 3400.15, clearly makes the connection between recognition of income and performance of the work ...
FCTD
Williams v. Canada (Minister of National Revenue), docket T-1646-97
Shelley, [1981] 2 S.C.R. 196 "> [1981] 2 S.C.R. 196: It is evident to me in this case that there is on the record no rational or necessary connection between the fact proved, i.e. possession of goods of foreign origin, and the conclusion of unlawful importation which the accused under s. 248(1) must, to avoid conviction, disprove. ...
FCTD
Tower v. Canada (Minister of National Revenue), 2002 FCT 929
At 5283, he put it as follows: Applying these principles, as I understand them, to materials prepared by accountants, in a general way, it seems to me (a) that no communication, statement or other material made or prepared by an accountant as such for a business man falls within the privilege unless it was prepared by the accountant as a result of a request by the business man's lawyer to be used in connection with litigation, existing or apprehended; and (b) that, where an accountant is used as a representative, or one of a group of representatives, for the purpose of placing a factual situation or a problem before a lawyer to obtain legal advice or legal assistance, the fact that he is an accountant, or that he uses his knowledge and skill as an accountant in carrying out such task, does not make the communications that he makes, or participates in making, as such a representative, any the less communications from the principal, who is the client, to the lawyer; and similarly, communications received by such a representative from a lawyer whose advice has been so sought are none the less communications from the lawyer to the client. ...
FCA
Gladstone Investment Corp. v. Canada, docket A-229-93
The money was not paid for change in or additions to the plaintiff"s premises or the buildings thereon or in connection with the structure of the plaintiff"s business. ...
FCTD
Maverick Oilfield Services Ltd. v. Canada (Attorney General), 2023 FC 1728
It is clear that the CRA accepts that there exists a causal connection between Mr. ...
FCA
Bank of Nova Scotia v. Canada, 2024 FCA 192, leave granted 22 May 2025 (41643)
We conclude that he was not satisfied the requisite strong causal connection existed between Methanex’s request and the reassessment. ...
TCC
Blackmore v. The Queen, 2013 DTC 1213 [at at 1147], 2013 TCC 264, aff'd 2014 DTC 5123 [at 7316], 2014 FCA 210
They have some sense of connection. There's a structure to it, right, so organizations have a sense of structure, and that typically includes some notion of who belongs and who doesn't belong. ... Cragun noted that the LDS Church today continues to disavow any connection to Mormon fundamentalists or groups that continue to practise polygamy, as Bountiful does. ... [256] I see no logical connection between these two phrases “beneficial ownership” and “in their own right.” ...
TCC
Wall v. The Queen, 2019 TCC 168, aff'd on other grounds 2021 FCA 132
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 Queen, [1978] C.T.C. 378, 78 D.T.C. 6281 (F.C.A.), the Chief Justice of the Federal Court stated at 384 (D.T.C. 6285) that the term “secondary intention”:... does no more than refer to a practical approach for determining certain questions that arise in connection with “trading cases” but there is no principle of law that is represented by this tag. ... Wall was in the business of developing properties and he developed the Three Homes as part of this business. (4) Work expended on or in connection with the property realized [162] It is apparent that Mr. ...
TCC
MacDonald v. The Queen, 2018 TCC 55
Further, in this appeal, it has to be noted that counsel for the Appellant did not ask permission to make submissions on costs at the close of the hearing on February 16, 2017. [22] However, I do agree with the Appellant that a party having made a valid settlement offer and having obtained a judgment as favourable as or more favourable than the settlement offer has a presumptive right to substantial indemnity costs. [23] The Federal Court of appeal in Venngo Inc v Concierge Connection Inc (Perkopolis), 2017 FCA 96, 146 CPR (4th) 182 [Venngo], reviewing Rule 420 of the Federal Courts Rule, the language of which is similar to the language of subsection 147(7) of the Rules, stated: 88 I agree with Venngo that the Federal Court committed a legal error in its assessment of CCI’s written offer to settle dated October 23, 2015. ...