Search - connection

Before concluding that the interchange fees were not zero-rated on the basis of the exclusion in VI‑IX‑1(a)(ii) for a service that “relates to (a) a debt that arises from … (ii) the lending of money that is primarily for use in Canada”, Sommerfeldt J found that: Regarding the “relates to” test, “there only needs to be ‘some connection’ between the interchange services and the debt described in the carve‑out, and the interchange services do not need to be ancillary or incidental to the debt” and the “ Slattery, Stantec and Miedzi Copper cases indicate that the phrases relating to, in relationship to, and, by extension, relates to, are to be given a wide or broad interpretation, and that a narrow view is to be avoided” (para. 54). ...

“Stewards,” being persons who had a commercial connection with such waste, were statutorily responsible for paying fees to SO to reflect their reasonable share of the associated costs. ...

Hershfield J found that ICBC received the settlement payment on its own account (as was in fact recognized in the settlement agreement) rather than on behalf of Mall Co in light inter alia of its own entitlements under the project agreements, including the right to require Tech BC to enter into the lease, and the fact that it had funded a substantial investment in IPL in connection with the project work for which it was being compensated. ...

.$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. ...

The Queen, 2016 TCC 172, aff'd 2018 FCA 124-- summary under Paragraph 20(1)(bb) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(bb) investment dealer fees re advisability of making hostile takeover were fully deductible The taxpayer, a Canadian public company listed on the TSX and NYSE and in Europe, 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. ...

On the facts of this case, the bonuses are not an entitlement from reserve land by virtue of the Appellant’s employment because there is no substantive connection between the land and the bonuses. ...

However, in my view, that remote a connection is not sufficient for one to conclude that the Unit Loans can reasonably be considered to relate to the gifts made by the Appellants to TGTFC. ...

The 2009 LP used these per-unit proceeds to pay $1,565 in issue expenses and $34,575 to purchase “Linked Notes” (issued by “Leeward,” a BVI corporation), which provided for the payment on their maturity on December 31, 2028 of their $34,575 principal plus the greater of two amounts, each calculated by reference to a notional portfolio consisting in one case of the performance of a notional balanced portfolio and in the second case, based on 200% of the appreciation in a specified stock index– and which, although secured, ranked behind the Notes issued by it in connection with the gifting component. ...

Paris, a retired KPMG accountant) had followed the advice of Montreal counsel in connection with the settling of the trust including depositing the initial "gift” of the taxpayer to the Trust of $2,000 in the name of the Trust, Owen J found (at paras 67, 68, 69, 70 and 73), and before vacating the reassessments: In my view, the fact that Mr. ...

In 2012, the taxpayer accepted (in connection with waiving any right of appeal pertaining to the 1995 and subsequent years) a settlement agreement which provided that much of the LP losses allocated to the investors would be allowed and that related interest and carrying expenses personally incurred by them also would be allowed and that capital gains from the dispositions of their units would be included in the computation of their income – but was silent as to the treatment of the gains that had been allocated to them by the LPs. ...