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Results 111 - 120 of 532 for connection
FCA

Hiwako Investments Ltd. v. The Queen, 78 DTC 6281, [1978] CTC 378 (FCA)

In my view, this term does no more than refer to a practical approach for determining certain questions that arise in connection with “trading cases’’ but there is no principle of law that is represented by this tag. ... In this connection, I see no difference between acquiring a profit-producing property and a capital asset for a business. ... See Anderson Logging, supra, CIR v Korean Syndicate, [1921] 3 KB 258, and Gloucester Railway Carriage and Wagon Co v CIR, (1924) 40 LTR 435. 5.“]: It is in connection with such cases that the question of secondary intention may arise. ...
FCA

Ville de Beauport v. Canada (Minister of National Revenue), 2001 FCA 198

(vii.1) reasonable allowances for the use of a motor vehicle received by an employee (other than an employee employed in connection with the selling of property or the negotiating of contracts for the employer) from the employer for travelling in the performance of the duties of the office or employment,... 6(1) Sont à inclure dans le calcul du revenu d'un contribuable tiré, pour une année d'imposition, d'une charge ou d'un emploi, ceux des éléments suivants qui sont applicables: b) les sommes qu'il a reçues au cours de l'année à titre d'allocations pour frais personnels ou de subsistance ou à titre d'allocations à toute autre fin, sauf: [...] (vii.1) Les allocations raisonnables pour l'usage d'un véhicule à moteur qu'un employé- dont l'emploi n'est pas lié à la vente de biens ou à la négotiation de contrats pour son employeur- a reçues de son employeur pour voyager dans l'accomplissement des fonctions de sa charge ou de son emploi [...] and for the purposes of subparagraphs 6(1)(b)(v), 6(1)(b)(vi) and 6(1)(b)(vii.1), an allowance received in a taxation year by a taxpayer for the use of a motor vehicle in connection with or in the course of the taxpayer's office or employment shall be deemed not to be a reasonable allowance (x) where the measurement of the use of the vehicle for the purpose of the allowance is not based solely on the number of kilometres for which the vehicle is used in connection with or in the course of the office or employment, or pour l'application des sous-alinéas (v), (vi) et (vii.1), une allocation reçue au cours de l'année par le contribuable pour l'usage d'un véhicule à moteur dans l'accomplissement des fonctions de sa charge ou de son emploi est réputée ne pas être raisonnable dans les cas suivants: (x) l'usage du véhicule n'est pas, pour la fixation de l'allocation, uniquement évalué en fonction du nombre de kilomètres parcourus par celui-ci dans l'accomplissement des fonctions de la charge ou de l'emploi, [5]                 The evidence established that the applicant had introduced a "motor vehicle allowance policy" based on figures contained in a specialized publication prepared by the Quebec Automobile Club (CAA-Quebec). ...
FCA

Danford Evan Eugene Bodrug and National Trust Company, Executors of the Estate of Evan Wesley Bodrug, Deceased v. Her Majesty the Queen in Right of Canada, [1991] 2 CTC 347

Cohen entered into an employment contract with Hidrogas and in connection therewith Mr. ... It seems clear that the cost of property may include brokerage fees, legal fees, commissions and other expenses incurred in connection with the acquisition of the property. ... The statutory remedy sought was that provided for in subsections 112(1) and (2) of the Securities Act, which read: 112. (1) Every insider of a corporation or associate or affiliate of such insider, who, in connection with a transaction relating to the capital securities of the corporation, makes use of any specific confidential information for his own benefit or advantage that, if generally known, might reasonably be expected to affect materially the value of such securities, is liable to compensate any person or company for any direct loss suffered by such person or company as a result of such transaction, unless such information was known or ought reasonably to have been known to such person or company at the time of such transaction, and is also accountable to the corporation for any direct benefit or advantage received or receivable by such insider, associate or affiliate, as the case may be, as a result of such transaction. (2) An action to enforce any right created by subsection (1) may be commenced only within 2 years after the date of completion of the transaction that gave rise to the cause of action. ...
FCA

Edmund Peachey Ltd. v. The Queen, 79 DTC 5064, [1979] CTC 51 (FCA)

But eventually you must have had some plans in connection with realizing your investment? ... The appellant’s submission in this connection reads as follows: By reason of the learned trial judge having found the appellant ceased carrying on the residential construction business well in excess of four years prior to the assessment by the Minister, the disposition of that property, by reason of Section 85E(1) was deemed to have taken place during the last year during which the appellant carried on business. ...
FCA

Allchin v. Canada, 2004 DTC 6468, 2004 FCA 206

Allchin's connections to the United States to sever her residential ties to Canada. ... After conducting a factual interpretation he concluded at paragraph 13 that Canadian residency had not been severed: I have carefully examined all of the relevant facts and I have concluded that there is no sufficient permanency involving the Appellant's connections to the United States that would result in the severing of the Appellant's residence ties to Canada in the 1993, 1994 and 1995 taxation years. ...
FCA

The Queen v. AEL Microtel Ltd., 86 DTC 6348, [1986] 2 CTC 108 (FCA)

They import such meanings as “in relation to”, “with reference to” or “in connection with”. The phrase “in respect of” is probably the widest of any expression intended to convey some connection between two related subject matters. ...
FCA

Gulfmark offshore N.S. Limited v. Canada, 2007 DTC 5563, 2007 FCA 302

As the business was carried on in connection with exploration and exploitation of the sea bed, the underlying activities came within article 27A of the Treaty. ...   [21]            As applied to the facts at hand, article 27A of the Treaty makes any U.K. resident, carrying on activities in Canada in connection with the exploration and exploitation of the sea bed, subsoil and natural resources for more than 30 days, liable to Canadian taxation as if it were carrying on a business through a permanent establishment. ...
FCA

Rath v. The Queen, 82 DTC 6175, [1982] CTC 207 (FCA)

Their contention that in the circumstances the interest should not be charged is based upon s 66 which is in these terms: “Subject to the provisons of this Act, the Exchequer Court shall have exclusive jurisdiction to hear and determine all questions that may arise in connection with any assessment made under this Act and in delivering judgment may make any order as to payment of any tax, interest or penalty or as to costs as to the said Court may seem right and proper.” ... The section is merely an enactment conferring upon the Exchequer Court exclusively the jurisdiction of dealing with disputes arising in connection with assessments made under the Act; and, as regards tax, interest and penalties, its powers are confined to seeing that they are only charged in strict accordance with the Act. ...
FCA

Canada v. 398722 Alberta Ltd., [2000] GSTC 32 (FCA)

.], and      (c) the making of a supply (other than an exempt supply) by the person of real property of the person, including anything done by the person in the course of or in connection with the making of the supply; [...]. [...] ... "commercial activity" of a person means      (a) a business carried on by the person (other than a business carried on by an individual or a partnership, all of the members of which are individuals, without a reasonable expectation of profit), except to the extent to which the business involves the making of exempt supplies by the person,      (b) an adventure or concern of the person in the nature of trade (other than an adventure or concern engaged in by an individual or a partnership, all of the members of which are individuals, without a reasonable expectation of profit), except to the extent to which the adventure or concern involves the making of exempt supplies by the person, and      (c) the making of a supply (other than an exempt supply) by the person of real property of the person, including anything done by the person in the course of or in connection with the making of the supply; [...]. [...] ...
FCA

Suermondt v. Canada, 2001 FCA 155

The applicant will be entitled to the costs incurred in connection with the application for judicial review.                                                                                                   ... The applicant will be entitled to the costs incurred in connection with the application for judicial review.                                                                                             ...

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