Search - connection

The Queen, 2012 TCC 105-- summary under Section 67 Summary Under Tax Topics- Income Tax Act- Section 67 The taxpayer, a lawyer, was bilked of $400,000 by scam artists, posing as clients, who induced him to pay for "processing " fees in connection with the recovery of a supposed container in the Ivory Coast containing US$8.5 million of cash. ...

Campbell J. found that their expenses in connection with the property, including mortgage expenses, were not deductible. ...

The Queen, 2004 DTC 2784, 2004 TCC 381 (Informal Procedure)-- summary under Subsection 2(1) Summary Under Tax Topics- Income Tax Act- Section 2- Subsection 2(1) After the taxpayer took an assignment (initially scheduled for two years) to work in Belize she maintained her home in Vancouver where her son and family resided, maintained her banking and financial interests in Canada, visited her connections in Vancouver approximately once per year, had no intention to reside on any permanent basis in Belize and considered Vancouver as a place where she could reconnect if need be. ...

Bowman C.J. stated (at p. 242) "residual friendships and employment connections do not create residency". ...

Before partially granting a motion for the filing of a list of administrative interpretations in connection with an appeal by a judge of a reassessment disallowing his RRSP deduction, Lamarre Proulx TCJ. stated (p. 1319) that she did not: "see why, if there are administrative interpretations concerning contributions to a pension plan and to a registered retirement saving plan which have been sent or made available to the judges in a general manner, a list of both administrative interpretations should not be produced for the purposes of this appeal. ...

La Reine, 2006 DTC 2969, 2004 TCC 688-- summary under Damages Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Damages Damages paid by the taxpayer in respect of the payment of a dividend to him by a corporation of which he was a director were not amounts incurred by him in connection with any business given that his directorship was not an office (as he was not entitled to any remuneration for acting in that capacity), and amounts earned for accounting services rendered to the company were earned by a corporation owned by him rather than him directly. ...

The Queen, 97 DTC 846, [1997] 1 CTC 2291 (TCC)-- summary under Substance Summary Under Tax Topics- General Concepts- Substance Payments made by Canadian franchisees to the taxpayer that were calculated as a mark-up on the value of products sold by the taxpayer to them were found not to be royalties for purposes of s. 212(1)(d) notwithstanding that, in order to avoid the application of the Robinson Patman Act, the franchise agreement provided that the mark-ups "shall be deemed to be considered a license fee charged for the license granted by the Franchise Agreement to Franchisee to use the Proprietary Marks in connection with the Franchisee's operation of an Entré Computer Center at the Center Location". ...

The Queen, 97 DTC 846, [1997] 1 CTC 2291 (TCC)-- summary under Paragraph 212(1)(d) Summary Under Tax Topics- Income Tax Act- Section 212- Subsection 212(1)- Paragraph 212(1)(d) Payments made by Canadian franchisees to the taxpayer that were calculated as a mark-up on the value of products sold by the taxpayer to them were found not to be royalties for purposes of s. 212(1)(d) notwithstanding that, in order to avoid the application of the Robinson Patman Act, the franchise agreement provided that the mark-ups "shall be deemed to be considered a license fee charged for the license granted by the Franchise Agreement to Franchisee to use the Proprietary Marks in connection with the Franchisee's operation of an Entré Computer Center at the Center Location". ...

He was prohibited from using the van other than for commuting to and from work and in connection with the performance of his duties. ...

., 99 DTC 926, [1999] 3 CTC 2036 (TCC)-- summary under Canadian Manufacturing and Processing Profits Summary Under Tax Topics- Income Tax Act- Section 125.1- Subsection 125.1(3)- Canadian Manufacturing and Processing Profits The taxpayer carried on a uniform rental business under which it agreed to lease uniforms to customers for a period generally of five years and, in that connection, would make alterations to affix identification tags and company crests and to wash and dry garments that it acquired for the lease. ...