Search - connection

Here, regarding s. 6(1)(b)(vii) “its wording requires that the employee be travelling away from the employer’s establishment … [whereas h]ere, Burnaby City Hall has no connection to the employer’s establishment so the allowance received by Mr. ...

., the doing of something in connection with the establishment of a commercial activity) (para. 46), so that there was a deemed acquisition by the Appellant of the property. ...

In finding (at para. 66) "that FHA was administering a government program in respect of homemaker services," as required by the preamble to s. 13(1)(b)(ii), Paris J stated (at para. 66) that "it is only necessary, then, to show some connection between the B.C. ...

Bountiful had no connection to the Church of Latter-Day Saints (the LDS church had explicitly rejected some key practices in Bountiful, including polygamy), nor the Fundamentalist Church of Latter-Day Saints (there is no such organization, but rather only people who self-identify as members), nor any other identifiable organization. ...

Before completion of the IPO, the Fund, Trust, appellant and its general partner entered into a "Financing Agreement" in which they agreed that all financing expense in connection with the IPO, other than the underwriters' fee, were to be incurred on behalf of the appellant; and at the same time the appellant entered into an "Administration Agreement" with the Fund in which it agreed to administer the Fund and "as agent of the Fund" to pay for all outlays and expenses incurred by it in such administration. ...

The Queen, 2016 TCC 137-- summary under Subsection 104(1) Summary Under Tax Topics- Income Tax Act- 101-110- Section 104- Subsection 104(1) TCC had jurisdiction to determine that no lender equitable remedy (under Quistclose trust doctrine) attached to leveraged donation advances In connection with a leveraged donation arrangement, the taxpayers in the lending agreement directed the lender (“Capital”) to deliver the funds to a charity on their behalf. ...

The Queen, 2016 TCC 172, aff'd 2018 FCA 124-- summary under Legal and other Professional Fees Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Legal and other Professional Fees investment dealer fees incurred respecting the advisability of making hostile takeover were fully deductible under s. 9 The taxpayer, a Canadian public company listed on the TSX, NYSE and LSE, incurred fees (mostly of investment dealers, law firms, and a French lobbying and public relations firm (“Publicis”)) in connection with its decision to make a hostile bid for a French public company (“Pechiney”) and the subsequent making and completion of that bid late in 2003. ...

The Queen, 2016 TCC 172, aff'd 2018 FCA 124-- summary under Eligible Capital Expenditure Summary Under Tax Topics- Income Tax Act- Section 14- Subsection 14(5)- Eligible Capital Expenditure fees incurred in order to acquire shares were excluded/butterfly expenses excluded as taxpayer was not in the business of implementing corporate reorganizations The taxpayer (“Alcan”) incurred various investment dealer, legal and other fees in connection with its successful hostile bid for most of the shares of a French public company (“Pechiney”). ...

Shortly thereafter, the trustee in bankruptcy who previously had been appointed to lead in connection with filing of the previous unsuccessful filing of a proposal, was replaced. ...

., that no statutory language used in or in connection with subsection 118(1) indicates that the deductions may be prorated for a taxation year, noting in contrast with other provisions in the Act by which Parliament has explicitly provided for proration. ...