Search - connection

Tax Treaty, which provided that a resident of a contracting state who carried on activities in the other state in connection with exploration or exploitation of the seabed and sub-soil and the natural resources situated in the other contracting state was deemed to be carrying on business in the other contracting state through a permanent establishment situated therein. ...

It was not clear which authority governed- the test in ExxonMobil that the allowance not be for the "exclusive personal use" of the employees, or the test in Midland Hutterian Brethren that there be a "functional connection between the needs of the business and the goods" (or services, in this case). ...

It was not clear which authority governed- the test in ExxonMobil that the allowance not be for the "exclusive personal use" of the employees, or the test in Midland Hutterian Brethren that there be a "functional connection between the needs of the business and the goods" (or services, in this case). ...

Salomon and Company Limited, [1897] A.C. 22 that a corporation is regarded in law as a legal entity with the personality of its own and it is quite distinct from its shareholders" (p. 1592), Christie A.C.J. found (at p. 1596) "that a person who acquires a share in a corporation does not thereby acquire an interest in land that is an asset of the corporation", and accordingly refused to extend the principle in the Fraser case to find that loans made to a real estate company by its shareholder had the same character as if they had been incurred in connection with the business of that company. ...

.$2.9 billion made to settle actions against it in connection with the Enron bankruptcy included whether the settlement amount should have been reimbursed to it by subsidiaries, whose conduct may have been the primary basis for the actions, in accordance with the transfer pricing rules. ...

.$2.9 billion made to settle actions against it in connection with the Enron bankruptcy, the Crown asked CIBC to approach its auditors (“EY”) to ask if they have any documents that matched defined search terms that CIBC used for documentary discovery, and to search for a multi-year period. ...

The Queen, 2016 TCC 11 (Informal Procedure)-- summary under Subsection 169(1) Summary Under Tax Topics- Income Tax Act- Section 169- Subsection 169(1) refusal to grant Reg. 105 waiver not an assessment/remedy in Federal Court CRA determined to not grant a waiver of withholding under Reg. 105 from fees to be paid to the appellants in connection with a proposed performance in Canada. ...

The Queen, 2016 TCC 52 (Informal Procedure)-- summary under Benefits-Conferring Legislation Summary Under Tax Topics- Statutory Interpretation- Benefits-Conferring Legislation interpretation to favour conferral of intended benefits In connection with finding that he addition of an accommodation co-purchaser (for financing purposes) of a new condo did not have the effect of denying the new housing HST rebate, Hershfield J stated (at paras. 50-51): In Rizzo & Rizzo Shoes Ltd. ...

Smith allowed the taxpayer’s claim for travel expenses of $30,418, stating (at para. 51): There is an obvious connection to the source of income, and while the amount is substantial, I am unable to conclude that it was unreasonable in the circumstances…. ...

In connection with considering an agency issue, D’Arcy J found that the Appellant had not established that the beneficial interests in Vacation Homes were held by it on behalf of its members, given inter alia that the risk of damage to the property through fire, misconduct of the users or normal wear and tear rested with the Appellant and the Resort Points represented only contractual rights to make reservations rather than being interests in the Vacation Homes. ...