Search - connection

Concierge Connection Inc. (Perkopolis), 2017 FCA 96 at paras. 11-12, 146 C.P.R. (4th) 182, leave to appeal refused, [2017] 2 S.C.R. x. ... Rather, the depreciation of goodwill is to be determined by the four-part test set out in Veuve Clicquot at para. 46: Firstly, that a claimant’s registered trade-mark was used by the defendant in connection with wares or services — whether or not such wares and services are competitive with those of the claimant. ...

The wide range of the exceptions permitted under subsection 8(2) unquestionably attests to the intention of Parliament to allow disclosure of personal information to persons who have no connection whatsoever with the disclosing institution and for purposes other than those for which the information was collected. [15]       Section 7 prescribes two possible uses of personal information collected by a government institution. ...

Justice Woods, as she then was, dismissed these arguments: [380]   The Minister also submits that the Treaty exemption was not intended to apply to the Trusts because they had very little connection with Barbados. ... It does not matter that the Trusts have few connections with Barbados. ...

The money was not paid for change in or additions to the plaintiff"s premises or the buildings thereon or in connection with the structure of the plaintiff"s business. ...

We conclude that he was not satisfied the requisite strong causal connection existed between Methanex’s request and the reassessment. ...

Accordingly, there is a real and direct connection between the expense claimed and the accounting firm ... In fact, in filing his income tax return for the year in issue, the appellant added US$100,000 he received for services rendered in connection with the legal proceeding to the amount he disbursed for the litigation and claimed the difference as a net loss resulting from this case. ...   [18]            Finally, for the reasons mentioned at paragraphs 30 to 33 of his reasons, I am of the opinion that the judge of the Tax Court was entitled to distinguish the appellant’s activities in connection with the sale of his client’s business from those in connection with the payment of a dividend ...

Is his exemption precluded because his connection is to more than one reserve? ... He has no less of a connection with a reserve simply because he had contact with 480 reserves. The connection must be established with each and every reserve, but need not be limited to just one. ...

Stated simply, income is located on a reserve if the relevant facts disclose a sufficient connection between the income and the reserve ... But he found that those connections to be insufficient to overcome the factors relating to the substantive aspects of the source of the corporate income – the fishing business – which did not have a substantial connection to the reserve ...   [8]                Justice Miller found no substantial connection between the operational aspects of the fishing business and any reserve. ...

It is legal fees incurred in connection with these proceedings, relating to the injunction and contempt of court, which appellant claims to be able to deduct in computing its income. ... The only problem arising in connection with them is as to whether they are amounts which were spent on capital account, the deduction of which is prohibited by paragraph 18(1)(b) of the Income Tax Act.* [1] The trial judge answered this question in the affirmative, because in his opinion these expenses were incurred in order to protect the very existence of the service station. ... With regard to the legal fees incurred by appellant in connection with the charges of contempt of court, the trial judge held that they should be likened to the fees incurred in opposing the injunction proceedings. ...

A deduction cannot be so far removed from its corresponding income stream as to render its connection to the anticipated income tenuous at best ... (emphasis added)       [15]            It may be relatively easy to establish a sufficiently close connection between an interest-free loan by a shareholder and an anticipated dividend. ... As the Judge pointed out, the direct connection was between the expenses and the business of the corporations.   ...