Search - connection
Results 21 - 30 of 534 for connection
FCA
Her Majesty the Queen v. MRT Investments Limited, [1976] CTC 294, [1976] DTC 6158
For the reasons given in connection with that appeal, I propose that this appeal be dismissed with costs and I direct that a copy of my reasons in that appeal, when transcribed, be placed on A-372-75. ...
FCA
The Queen v. Blanchard, 95 DTC 5479, [1995] 2 CTC 262 (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. ... That section, if I am to respect its unambiguous wording, requires only some connection between the receipt of a payment and the recipient’s employment-nothing seems to turn on the source of the payment. ...
FCA
Brake v. Canada, 2013 FCA 172
Brake made to a corporation owned by himself and his spouse, and loans he made to his spouse in connection with her own sole proprietorship, to enable them to pay their respective business expenses. ... [6] For the purpose of subparagraph 20(1)(p)(i), a debt owed to a taxpayer can be said to have been included in the taxpayer’s income only when the debt represents unpaid revenue that has been earned by the taxpayer in connection with a business or property, if the revenue was included in income. ...
FCA
Canada v. Robertson, 2012 DTC 5077 [at at 6945], 2012 FCA 94
In any event, he held (at para. 101), the Appellants’ relationship with the Co-op, and their “activities’ historical, cultural and economic connection with the reserve … create a compelling connection to the reserve ... [62] That the Appellants’ fishing business may have connections with markets off-reserve does not weaken the connection of the resulting income to the Reserve. ... [76] First, it is immaterial that the ultimate customers, that is, those who buy from Freshwater, have no connection with a reserve. ...
FCA
Mendoza v. Canada, 2003 DTC 5071, 2003 FCA 17 (FCA)
He also found that the expenses claimed in connection with the Chester Street property were not deductible because this was the primary residence of the Applicants and the space was not used exclusively for their business. [6] The second issue relates exclusively to the Hornby property. ... In doing so he considered that the evaluation of whether there was a reasonable expectation of profit was to be an objective determination, taking into account the factors of (a) profit and loss experience in other years; (b) the nature of the expenses (c) whether there was a personal element (d) whether there was an existence or absence of a plan which would indicate a reasonable expectation of profit In the result, the Tax Court Judge disallowed the expenses in connection with the Hornby property. [9] On this application the Applicants argued that the Tax Court Judge had erred in his appreciation of the facts in making his decision on the deductibility of the expenses relating to the Express partnership. ... It was the Applicants' submission, having regard to the Stewart case, that the Tax Court Judge had erred by applying the reasonable expectation of profit test in connection with the claim for expenses on the Hornby property. [11] In Stewart, the Supreme Court said at paragraph 60 In summary, the issue of whether or not a taxpayer has a source of income is to be determined by looking at the commerciality of the activity in question. ...
FCA
Leon v. MNR, 76 DTC 6303, [1976] CTC 541 (FCA)
Leon shall employ Nor-Mar to take charge of and be responsible for all promotion and public relation work which may be required in connection with the operation of any stores owned by Leon whether these stores may be owned at this date or may be hereafter acquired. 2. Nor-Mar shall devote its full time and effort to properly complete and fulfill all duties which are normally allocated to a person or corporation charged with promotion and public relations work and specifically in connection with stores engaged in the business herein above referred to. 3. ... I find that the respondent Norman Leon has not discharged the onus which is on him to establish that the position of the appellant in connection with the assessments in the Norman Leon matter, the basis for making them or the appellant’s relevant assumptions were wrong. ...
FCA
Arthur S. Donovan v. Her Majesty the Queen, [1996] 1 CTC 264, [1996] DTC 6085
In our view he was also correct in concluding that the value of the benefit was not reduced by credit balances in the shareholders loan accounts for the years in question as there was no connection between the loan and the costs incurred in acquiring the property. ...
FCA
Midland Hutterian Brethren v. Canada, [2000] GSTC 109 (FCA)
This Court has already interpreted these words to mean that, when a registrant incurs a GST expense in connection with its commercial activities, it is entitled to an ITC. ... I agree that, for the goods to be acquired for use "in the course of commercial activities", there must be a functional connection between the needs of the business and the goods. ... In my view, the disputed phrase is sufficiently open-textured that, as a linguistic matter, it is not determinative of the degree of connection with the commercial activity necessary to justify an ITC. ...
FCA
The Queen v. Shilling, 2001 FCA 178
Shilling has lived most of her adult life in Toronto, she has maintained her connections with the Rama reserve, which she visits regularly and considers to be her home. ... Shilling, it is difficult to discern a strong connection between the location of the employer and the purpose of section 87. ... There is no evidence that NLS had any connection to the Rama Band of which Ms. ...
FCA
Laliberté v. R., 98 DTC 6604, [1999] 2 CTC 178 (FCA)
However, the $20,000 loaned by the first mortgage creditor to the applicant’s husband in 1986 had been borrowed not to produce income, but to pay legal costs in connection with a civil suit unrelated to the rental property. ...