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Results 6151 - 6160 of 6337 for connection
TCC
Morrison v. The Queen, 2018 TCC 220, aff'd sub nom. Eisbrenner v. Canada, 2020 FCA 93
Eisbrenner each testified that there was no connection between the cash donation identified in the promotional materials as “ Stage 1 ” and the balance of the steps identified in the promotional materials as “ Stage 2 ”, and that there was no obligation to make a cash donation to be considered as a potential Class A beneficiary of CHT. [41] [36] Mr. ... Rosenberg and Marigold recommend thus have no connection with the transactions prices actually charged and received by manufacturers for generic drugs in Canada. ...
FCTD
Canadian Association of Refugee Lawyers v. Canada (Citizenship and Immigration), 2019 FC 1126
In my view, this objection is more appropriately addressed in connection with the issue that CARL has raised regarding the Chairperson’s failure to consult with the public before issuing the China JG. [82] CARL also maintains that it is improper to raise a factual finding to the level of a jurisprudential guide because country conditions are constantly changing. ... In connection with transportation and travel, the JG also notes that consideration must be given to Chairperson Guidelines 4: Women Refugee Claimants Fearing Gender-Related Persecution. [118] The JG concludes with the statement that “it is my view tha[t] an assessment in line with the framework set out above would be broadly applicable and determinative in a variety of Nigerian claims where the fear is of non-state actors, and as below, would have to be applied in any individual appellant’s particular circumstances ”: at para 30 (emphasis added). [119] Considering the passages that I have underlined in the various quotes above, I am satisfied that the Nigeria JG does not unlawfully fetter the discretion of Board members or improperly constrain their freedom to decide cases that may come before them according to their own conscience. ...
FCA
HEILTSUK HORIZON MARITIME SERVICES LTD. v. ATLANTIC TOWING LIMITED et al. AND DOCKET: A-57-19 STYLE OF CAUSE: HEILTSUK HORIZON MARITIME SERVICES LTD. et al. v. ATLANTIC TOWING LIMITED et al. AND DOCKET: A-428-19 STYLE OF CAUSE: ATLANTIC TOWING LIMITED v. HEILSTUK HORIZON MARITIME SERVICES LTD. et al. AND DOCKET: A-430-19 STYLE OF CAUSE: HEILTSUK HORIZON MARITIME SERVICES LTD. v. ATLANTIC TOWING LIMITED et al. AND DOCKET: A-433-19 STYLE OF CAUSE: ATTORNEY GENERAL OF CANADA v. HEILTSUK HORIZON MARITIME SERVICES LTD. et al., 2021 FCA 26
Heiltsuk Horizon ranked last. [3] Heiltsuk Horizon, which filed four complaints with the Tribunal in connection with the Solicitation, as permitted by the Canadian International Trade Tribunal Act, R.S.C. 1985, c. 47 (4th Supp.) ... Heiltsuk Horizon explained at the hearing that it had made a strategic choice not to file reply evidence with respect to the New Evidence based on its understanding that vessel substitution was permitted by the RFP. [185] Whether this view is supported by the terms of the RFP need not be decided here in light of my findings on the merits of all five applications for judicial review, which seal the fate of Heiltsuk Horizon’s four complaints filed with the Tribunal in connection with the Solicitation. [186] In sum, I see no reason to award costs to Atlantic on a solicitor-client basis. ...
TCC
Norton v. R., [1998] 1 CTC 3197, 97 DTC 1116
Most of the sales were handled by Ken Holloway on a one-on-one basis when people would visit the offices of Thill Inc. in connection with another matter as the business of Thill Inc. included provision of financial advice and preparation of income tax returns. ... Thill, personally, received the sum of $29,894 and $11,600 went to Thill Inc. while another $78,785 was paid in commissions to people in connection with the sale of a variety of partnership units. ...
FCA
Alliance for Life v. Minister of National Revenue, [1999] 3 CTC 1
In this same connection, lacobucci J. added the following at paragraph 158: The chief proposition to be drawn from this holding is that even the pursuit of a purpose which would be non-charitable in itself may not disqualify an organization from being considered charitable if it is pursued only as a means of fulfilment of another, charitable, purpose and not as an end in itself. ... The learned author opined in this same connection that “there is little doubt that, if the genuine and sole object is to enlighten the public on the theories and concepts of political belief in general, this is educational”. ...
TCC
Coté v. R., [1999] 3 CTC 2373
He was prohibited from acting directly or indirectly as an appraiser, promoter, broker or consultant in connection with gifts of works of art to non-profit organizations, such as charities, and in particular museums and fabriques. ... Demers also made a connection between invoices from the Galerie des Maîtres Anciens and Univers du Rail Inc. ...
TCC
3295940 Canada Inc. v. The Queen, 2022 TCC 68, rev'd 2024 FCA 42
To avoid the tax payable in connection with the unrealized capital gain, they simply had to sell their stake. ... The Company will keep RoundTable informed of all arrangements entered into by its shareholders in connection with the Proposed Transaction and provide adequate documentation in respect thereof. 11 See Authier transcription, Appendix 8, pp. 58–60. 12 See the letter of intent dated January 25, 2002, Appendix 10. ...
TCC
Marine Atlantic Inc. v. The King, 2023 TCC 95
Hupman’s words, had a connection to both the making of the taxable supplies and the making of the exempt transportation service. ... Finally, if the area had a connection to both the taxable supplies and the exempt supplies, meaning that it was intended to be used directly or indirectly for both, then it was treated as a common area. [132] It is the Appellant’s position that the extent to which it acquired, imported or brought into a participating province property or services for consumption, use, or supply in the course of its commercial activities can be determined by taking the total square metres of all areas of the Vessels that were used exclusively in the making of taxable supplies for consideration and dividing this figure by the total of the square metres of all areas of the Vessels that were used exclusively in the making of taxable supplies for consideration and the square metres of all areas of the Vessels that were used exclusively in the making of exempt supplies. [133] Originally, the Appellant had used the following formula: the total square metres of the areas of the Vessels used in making taxable supplies divided by the difference between the total area of the Vessels and the total square meters of the common areas of the Vessels [28]. ...
TCC
Chan v. Canada (Employment, Workforce Development and Official Languages), 2024 TCC 83
It is therefore appropriate to consider each case as being unique rather than assuming that a specific financial vehicle will always produce an annuity or a pension. [38] The Court went on to conclude that, in the appellant’s circumstances, the lump sum payment from his life income fund was not pension income for purposes of computing his 2012 estimated income under the option method. [39] In this reference, the Respondent embraces the observation in L é vesque that a regular stream of annual payments from an RRIF would cause those payments to be pension income and urges me to apply that same reasoning here to find that the Appellant’s 2018 and 2019 lump sum RRIF withdrawals were both payments that constituted pension income within the meaning of section 14 of the OAS Regulations. [40] Factually, the Respondent’s position is based on the notion that, to qualify as an RRIF under the provisions of the ITA and Income Tax Regulations, [5] the terms of an RRIF must provide for annual minimum withdrawals by the annuitant of a prescribed percentage of the fair market value of all properties held in connection with the fund at the end of the year, starting on the calendar year following the one in which the annuitant established the plan. ... Income-Related Question – Subsections 12(6) and 12.1(1) of the OAS Act [100] If the nature of the Minister’s determination under appeal by the Appellant is the individual’s ultimate entitlement to GIS benefits from the payment periods covered by the determination, sections 12 and 12.1 seem to be the only OAS Act provisions that fix the amount of GIS benefits that an individual is entitled to receive for a month in a payment period. [101] As discussed earlier, there are income-related questions that arise under sections 12 and 12.1 in connection with the claw back mechanism used to implement income-testing for the GIS. ...
SCC
Piekut v. Canada (National Revenue), 2025 SCC 13
Section 178(1.1) provides: (1.1) At any time after five years after the day on which a bankrupt who has a debt referred to in paragraph (1)(g) or (g.1) ceases to be a full- or part-time student or an eligible apprentice, as the case may be, under the applicable Act or enactment, the court may, on application, order that subsection (1) does not apply to the debt if the court is satisfied that (a) the bankrupt has acted in good faith in connection with the bankrupt’s liabilities under the debt; and (b) the bankrupt has and will continue to experience financial difficulty to such an extent that the bankrupt will be unable to pay the debt ... g) de toute dette ou obligation découlant d’un prêt consenti ou garanti au titre de la Loi fédérale sur les prêts aux étudiants, de la Loi fédérale sur l’aide financière aux étudiants ou de toute loi provinciale relative aux prêts aux étudiants lorsque la faillite est survenue avant la date à laquelle le failli a cessé d’être un étudiant, à temps plein ou à temps partiel, au regard de la loi applicable, ou dans les sept ans suivant cette date; [136] Also relevant to the scheme is s. 178(1.1): (1.1) At any time after five years after the day on which a bankrupt who has a debt referred to in paragraph (1)(g) or (g.1) ceases to be a full- or part-time student or an eligible apprentice, as the case may be, under the applicable Act or enactment, the court may, on application, order that subsection (1) does not apply to the debt if the court is satisfied that (a) the bankrupt has acted in good faith in connection with the bankrupt’s liabilities under the debt; and (b) the bankrupt has and will continue to experience financial difficulty to such an extent that the bankrupt will be unable to pay the debt ...