Search - connection
Results 71 - 80 of 6336 for connection
FCTD
Canadian Pacific Railway Company v. Canada, 2022 FC 392
While they may not be appropriate in all cases, where they achieve the benefits mentioned above, lump sum awards also further the objective of securing the “just, most expeditious and least expensive determination” of proceedings (Allergan at paras 22-23 and Nova Chemicals at para 11, both citing Rule 3 of the Rules; see also Venngo Inc v Concierge Connection Inc, 2017 FCA 96 [Venngo] at paras 85-86, leave to appeal ref’d [2017] SCCA No 302; Consorzio at para 12). [26] The amount chosen as an appropriate contribution towards the successful party’s costs is not an exact science warranting a granular analysis. ...
FCTD
Tekna Plasma Systems Inc. v. AP&C Advanced Powders & Coatings Inc., 2024 FC 1954
In addition to these requirements in the rule, the jurisprudence requires the offer to be clear and unequivocal, to contain an element of compromise or “incentive to accept,” and to bring the litigation to an end: Venngo Inc v Concierge Connection Inc (Perkopolis), 2017 FCA 96 at para 87, citing H‑D USA, LLC v Berrada, 2015 FC 189 [Berrada] at para 32 and Syntex Pharmaceuticals International Ltd v Apotex Inc, 2001 FCA 137 at para 10. [28] Where a plaintiff makes such an offer, and obtains a judgment as or more favourable than its terms, it is entitled to party-and-party costs to the date of the offer, and to costs calculated at double that rate, but not double disbursements, from that date to the date of judgment, unless the Court orders otherwise: Federal Courts Rules, Rule 420(1). ...
TCC
Rudolph v. The King, 2024 TCC 148
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. ...
SCC
Dow Chemical Canada ULC v. Canada, 2024 SCC 23
With respect, this is inconsistent with the distinct routes of appeal to the Tax Court from other decisions of the Minister that are set out expressly in the ITA. [66] Where Parliament provided for recourse from a ministerial decision to the Tax Court, it did not rely on an implicit connection to the assessment, but rather created an express right to appeal that decision. ... As Dow notes, s. 66 of the former IWTA provided the Exchequer Court “exclusive jurisdiction to hear and determine all questions that may arise in connection with any assessment made under this Act and in delivering judgment may make any order as to payment of any tax, interest or penalty . . . as to the said Court may seem right and proper” (see A.F., at para. 119 (emphasis added)). ...
TCC
Leonard v. The Queen, 2021 TCC 33, rev'd 2022 FCA 195
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. ...
TCC
ONEnergy Inc. v. The Queen, 2016 TCC 230, rev'd 2018 FCA
This seems to be the essence of the connection claimed, and it is very much a “but for” connection. [20] What I suggest is at issue in looking at this from a strictly textual broad interpretation of “in connection with” is whether a corporation can ever be considered to incur a “personal expense” or is every expense “in connection” with its business? ... No, not in the sense I find a connection is required given the context and purpose. ... I emphasize it is the connection that is paramount, not the timing of the activity. ...
TCC
Castela v. The Queen, 2005 DTC 781, 2005 TCC 109 (Informal Procedure)
In the general exclusion any connection, in the broadest sense, should suffice. ... The subject provision of the Act does not speak of such potential connections. ... Nor was it in connection with her duties of employment. Rather, it was in connection with her profession. ...
TCC
Cunningham v. The Queen, 2005 TCC 455 (Informal Procedure)
It is unlikely that the program in these circumstances is “taken” in connection with the employment ... I agree with counsel for the Crown that the words “in connection with” are broad but in my view an insubstantial connection is not sufficient ... I note that it is not sufficient to have a connection to a field of endeavour or profession. ...
ONCA decision
St. Mary’s Anglican Church Et Al. v. Assessment Commissioner of the City of Windsor, [1942] CTC 226
All property in this Province shall be liable to taxation, subject to the following exemptions, that is to say: "‘(3) Every place of worship, and land used in connection therewith, churchyard or burying ground. ... All property in this Province shall be liable to taxation, subject to the following exemptions, that is to say: "‘(3) Every place of worship, and land used in connection therewith, churchyard or burying ground; but land on which a place of worship is erected, and land used in connection with a place of worship, shall be liable to be assessed for local improvements in the same way and to the same extent as other land.’’ ... In my opinion the land upon which a parsonage is built, is not land used in connection with a place of worship, much less is the parsonage erected on land used in connection with a place of worship. ...
AltaAssComm decision
In Re Assessment Act v. In Re Hudson’s Bay Company., [1938-39] CTC 418
This objection must assume, of course, that the vessels in question are personal property used in connection with the company’s warehouse at Waterways, for it was in connection with that warehouse that a business assessment of $120 was made for the year 1938. It may be said that the Commission is not prepared to assume that these vessels, valued at some $126,000, are used in connection with the warehouse in question. It would seem more logical for the Commission to assume that the warehouse in question was used in connection with the vessels rather than that the vessels were used in connection with the warehouse. ...