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Results 221 - 230 of 1117 for connection
FCA (summary)
Canada v. Akiwenzie, 2004 DTC 6007, 2003 FCA 469 -- summary under Section 87
Noël J.A. stated (at p. 6010) that "it cannot be said that the taxation of the respondent's income would result in the erosion of his entitlement qua Indian on any or all of these reserves as there is no connection whatsoever between this income as such and these reserves as economic bases or physical location.... ...
TCC (summary)
Ouellet v. The Queen, 94 DTC 1315, [1994] 1 CTC 2645 (TCC) -- summary under Interpretation Bulletins, etc.
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. ...
FCTD (summary)
Border Chemical Co. Ltd. v. The Queen, 87 DTC 5391, [1987] 2 CTC 183 (FCTD) -- summary under Legal and other Professional Fees
The Queen, 87 DTC 5391, [1987] 2 CTC 183 (FCTD)-- 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 Legal fees paid by the taxpayer for the successful defence of its president against fraud charges brought in connection with alleged activities in which the taxpayer had no direct involvement, were non-deductible. ...
Decision summary
Pepper v. Hart, [1992] BTC 591 (HL) -- summary under Paragraph 6(1)(a)
In finding that this did not give rise to a taxable benefit under a section which referred to the "expense incurred in or in connection with" provision of in-house benefits, it was found that this section referred to the additional expenses attributable to each boy (such as food, stationery and laundry) rather than a proportion of all the running expenses of the school. ...
TCC (summary)
St-Georges c. La Reine, 2006 DTC 2969, 2004 TCC 688 -- summary under Damages
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. ...
SCC (summary)
Highway Sawmills Limited v. Minister of National Revenue, 66 DTC 5116, [1966] CTC 150, [1966] SCR 384 -- summary under Scheme
Minister of National Revenue, 66 DTC 5116, [1966] CTC 150, [1966] S.C.R. 384-- summary under Scheme Summary Under Tax Topics- Statutory Interpretation- Scheme In connection with finding that land upon which the timber had been removed should be regarded as part of a timber limit, in order to avoid the deduction by the taxpayer of depreciation in excess of the net cost to it of the land, Cartwright J. stated (p. 5120): "The answer to the question what tax is payable in any given circumstances depends, of course, upon the words of the legislation imposing it. ...
FCTD (summary)
Sheridan Warehousing Ltd. v. R., 83 DTC 5095, [1983] CTC 90 (FCTD) -- summary under Paragraph 239(1)(f)
., 83 DTC 5095, [1983] CTC 90 (FCTD)-- summary under Paragraph 239(1)(f) Summary Under Tax Topics- Income Tax Act- Section 239- Subsection 239(1)- Paragraph 239(1)(f) It was stated, in connection with a case where the accused had corroborated the V-day value of land with false documentation, that: "I do not conceive how any precise finding of value dependent on the opinion evidence of experts in land valuation could be arrived at beyond a reasonable doubt [:] R. v. ...
TCC (summary)
Entré Computer Centers Inc. v. The Queen, 97 DTC 846, [1997] 1 CTC 2291 (TCC) -- summary under Substance
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". ...
TCC (summary)
Entré Computer Centers Inc. v. The Queen, 97 DTC 846, [1997] 1 CTC 2291 (TCC) -- summary under Paragraph 212(1)(d)
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". ...
TCC (summary)
MacMillan v. The Queen, 2005 DTC 1243, 2005 TCC 583 (Informal Procedure) -- summary under Paragraph 6(1)(e)
He was prohibited from using the van other than for commuting to and from work and in connection with the performance of his duties. ...