Search - connection

In this connection what is the effect of the leases previously referred to? ... Accordingly, I consider that the phrase “use in connection with a business carried on by him” does not limit the planned structure to one which would be a facility in connection with the taxpayer’s business. ... Services of solicitors for documentation in connection with the above matters. 7. ...

That is a clear connection to the new residence. There were no intervening events, no intervening deposits or withdrawals. ... One argument was that the section does not speak to "connections" and for the Respondent to rely on connections is just not something that is found in the words of the Act. ... This has resulted in a connection between his equity loan and the new residence. ...

Whether there need be any “connection” between farming and the other source of income. ... As I construe his Lordship’s statement in its context, he did not consider “connection” a requirement. ... As I construe it, there is nothing in subsection 13(1) which says there must be any such connection. ...

Since the measurement of the use of the vehicle must be based solely on the number of kilometres for which the vehicle is used in connection with or in the course of the office or employment, it will just as readily be understood here that the use of the vehicle cannot be measured based on the number of days for which it was used in connection with or in the course of the office or employment. ... In both cases, the use of the vehicle is not measured on an individual basis solely according to the number of kilometres travelled by a given employee in connection with his employment. ... Under such a scheme one would have to determine the allowance of each employee based on the number of kilometres actually travelled by that employee in connection with his employment. ...

For ease of reference I will refer to the factors in Rule 147(3) by their paragraph numbers. [6]   In connection with paragraph (a) the Respondent was totally successful in having the motion dismissed with costs. There was absolutely no merit to the Appellants position. [7]   In connection with paragraph (b) the Respondent agrees that while the amounts in issue with respect to these particular Appellants are not overly large, that the total amounts in issue for all the cases impacted by these lead cases exceeds over $600 million and therefore is huge. ... In my opinion, the Appellants should have attempted to work out its undertaking concerns, but clearly had no intention of doing so. [10]   In connection with paragraph (e) dealing with volume of work, I am in complete agreement with the Respondent that the volume of work in connection with this motion was enormous. ...

Blackburn deducted legal fees of $4,500 and $10,500 respectively, in connection with this criminal matter. ... He deducted legal fees in 2000 in connection with this matter and was denied such deduction by Canada Revenue Agency. ... Blackburn claimed were in connection with the internal Police Services Act matter, Mr. ...

I agree. [9]      In order to determine if the Appellant was a resident of Canada in the 1993, 1994 and 1995 taxation years I will outline the Appellant's connections to Canada and the Appellant's connections to the United States. ... In connection with her allegation that she lived on her boat I note that Tab 3 of Exhibit A-1 contains a copy of a lease dated January 20, 1996 between the Appellant and the Shore Club Marina. ... I find that her connections to the United States were of a very temporary nature. ...

T he findings of fact of the Tax Court of Canada judge disclose no such connections in this case.  ... That symmetry was found in Williams to strengthen the connection between the place of employment and the benefits. ... I‑5  , to apply to an Indian’s personal property, the property must have concrete and discernible connections with a reserve. [35]                           In the instant case, the findings of fact of the Tax Court of Canada judge disclose no such concrete connections.  ...

The Appellant has submitted a claim to the Respondent on account of medical expenses with respect to her 1995 taxation year (for medical expenses in connection with the period January 1, 1995 to December 31, 1995) in the amount of $4,907.35. 3. ... The difference between the position of the Appellant and the position of the Respondent in connection with the medical expense claim relates solely to the item respecting "travel-use of personal vehicle": (a) The Appellant has made a medical expense claim of $1,361.25 in connection with this item ($0.30 per kilometre); (b) The Respondent has allowed only $604.67 in connection with this item ($0.16 per kilometre). 5. The amount per kilometre that the Respondent has suggested as being reasonable is $0.16 per kilometre, being the amount that the Respondent is prepared to allow in connection with "travel-use of personal vehicle". 6. ...

Accordingly, there is a real and direct connection between the expense claimed and the accounting firm ... In fact, in filing his income tax return for the year in issue, the appellant added US$100,000 he received for services rendered in connection with the legal proceeding to the amount he disbursed for the litigation and claimed the difference as a net loss resulting from this case. ...   [18]            Finally, for the reasons mentioned at paragraphs 30 to 33 of his reasons, I am of the opinion that the judge of the Tax Court was entitled to distinguish the appellant’s activities in connection with the sale of his client’s business from those in connection with the payment of a dividend ...