Search - connection

Nor was it in connection with her duties of employment. Rather, it was in connection with her profession. ... Nor is it even "in connection with" School District No. 23 any more than the calling of being a janitor is in connection with School District No. 23. ... Connection ("connexion") is: The action of connecting; the condition of being connected. ...

It must have been a very small percentage of the total cost of making the connections to all of the 77 lots. ... In the present case we are concerned with the amount paid for water and sewer connections. The person (Red River Construction (1972) Limited) who made the connections and was paid for so doing, IS a private construction company. ...

The Appellant's liability under the First Guarantee was to a maximum of $351,574.73. [6]      On the 9th day of August 1995 the Appellant provided a second joint and several guarantee to the Bank in connection with a further loan obtained by Alliance (the "Second Guarantee"). ... This demand for payment was made in connection with the First Guarantee that the Appellant provided to the Bank. [8]      By letter dated the 24th day of June 1997 the solicitors for the Bank wrote to the Appellant demanding that the Appellant pay the Bank the sum of $11,329.35 immediately. This demand for payment was made in connection with the Second Guarantee that the Appellant provided to the Bank. [9]      The Appellant retained the services of a law firm to obtain advice in connection with his liability under the First Guarantee and the Second Guarantee that he provided to the Bank. ...

This statement implies that such a connection may have been established had the evidence been presented. ...   [23]          Parliament could have used different language in drafting section 122.3 to convey a stronger connection to qualifying activities. ... When Justice Woods in Humber concluded that the connection, between the training offered by the CNA-Q campus and the engineering activities of the Qatar oil and gas sector, was too remote, it appeared to be because there was insufficient evidence before the Court in that appeal to establish this connection, unlike the oral and documentary evidence that sufficiently established such a connection in the present appeal ...

Guaranteed Homes Ltd., [1978] C.T.C. 636, 78 D.T.C. 6510 (F.C.T.D.) is the leading case dealing with the deductibility of the costs of service connections pursuant to paragraph 20(1)(ee). ... Crown’s counsel in Guaranteed Homes submitted that paragraph 20(1)(ee) is clearly intended to grant a right of reduction to a person who has his place of business at a certain location, to which location the service connections are made, and in which location that person, as operator of the business, will be the recipient of the services that are made available by the installation of the connections. ... The service connections were not made to the appellant’s place of business. ...

To put it simply, subsection 6(2) now provides that if all or substantially all of the distance travelled by the automobile in the total available days is in connection with or in the course of the office or employment, the value of benefit will be reduced to a proportion of 1,000 kilometres a month or 12,000 kilometres a year if the total number of kilometres driven (otherwise than in connection with or in the course of the taxpayer's office or employment) during the total available days is less than 1,000 kilometres a month or 12,000 kilometres a year. [10]     In my opinion, the evidence as presented indicates that both conditions have been satisfied in the present case. First, substantially all of the distance travelled meaning 90% or more of the distance travelled, during the years in issue was in connection with or in the course of the Appellant's employment with the company. Second, the distance travelled otherwise than in connection with the Appellant's employment was an average of 125 kilometres a month. [11]     From the foregoing, the appeals are allowed and the assessments are referred back to the Minister for reconsideration and reassessment pursuant to paragraph 6(1) (e) and subsection 6(2) as well as under paragraph 6(1) (k) of the Act on the basis that substantially all of the distance travelled with the automobile was in connection with or in the course of the Appellant's employment and that the distance travelled otherwise than in connection with or in the course of that employment was 125 kilometres a month for 11 months in 1997 and 12 months in 1998. ...

In the assessments the Minister of National Revenue increased the amount of taxable benefits arising from the appellant's use of an employer-owned automobile. [2]      The only issue before me is whether the appellant's use of the automobile is "all or substantially all" in connection with her employment. ... Sherlock is in the business of managing rental real estate. [5]      According to the appellant's testimony, she used the automobile frequently in connection with her employment which involved managing the following rental properties: a 40-unit apartment building in Burnaby, B.C., a residential property in Vancouver and two condominiums in Whistler. [6]      Pursuant to the relevant statutory provisions, the taxable benefits arising from the use of the automobile can be reduced if "all or substantially all of the distance traveled by the automobile in the total available days is in connection with or in the course of the office or employment. ... There was no supporting documentation for the remaining 60 trips; (b)              Nine trips to Sherlock's accountant and lawyer; (c)               54 trips in connection with other rental properties, including six trips to Whistler; and (d)              12 trips to purchase office supplies. [11]     The above estimates were based largely on the appellant's recollection except for the 108 trips supported by the bank deposit slips. ...

  [11]     The connection was not described by the representative as clearly as I would have liked. ...   [14]     There is clearly some connection between CNA’s business and engineering activities. ... Such a remote connection cannot be what Parliament intended in section 122.3 ...

The statement has no probative value because it does not prove this connection, simply corroborating the tragic incidents. ... When he speculates, assumes and presumes, that in no way establishes a connection between the deaths and attacks to seek revenge or to intimidate. ... What is sorely lacking is a plausible connection between the tragic deaths and the alleged fear, when even the police officer uncle does not claim one. ...

It is the benefit and advantage of the good name, reputation and connection of a business. ... While this business connection which the appellant had was an asset its transferable value could not be otherwise than very small. ... Moreover, the connection which he had was largely personal to himself and his two salesmen. ...