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Results 201 - 210 of 532 for connection
FCA
Alberta Institute on Mental Retardation v. The Queen, 87 DTC 5306, [1987] 2 CTC 70 (FCA)
(j) “related business" — “related business” in relation to a charity includes a business that is unrelated to the objects of the charity if substantially all of the people employed by the charity in the carrying on of that business are not remunerated for such employment; [Emphasis added.] 149.1(2) Revocation of registration of charitable organization — The Minister may, in the manner described in section 168, revoke the registration of a charitable organization for any reason described in subsection (1) of that section or where the organization (a) carries on a business that is not a related business of that charity; or (b) fails to expend in any taxation year, on charitable activities carried on by it and by way of gifts made by it to qualified donees, amounts that, in the aggregate, are at least equal to the amount that would be determined for the year under subparagraph (1)(e)(i) in respect of the organization if it were a charitable foundation. (3) Revocation of registration of public foundation — The Minister may, in the manner described in section 168, revoke the registration of a public foundation for any reason described in subsection (1) of that section or where the foundation (a) carries on a business that is not a related business of that charity; (b) fails to expend in any taxation year, on charitable activities carried on by it and by way of gifts made by it to qualified donees, amounts that, in the aggregate, are at least equal to its disbursement quota for that year; (c) since June 1, 1950, acquired control of any corporation; (d) since June 1, 1950, incurred debts, other than debts for current operating expenses, debts incurred in connection with the purchase and sale of investments and debts incurred in the course of administering charitable activities; or (e) at any time within the 24 month period preceding the day on which notice is given to the public foundation by the Minister pursuant to subsection 168(1) and at a time when the public foundation was a private foundation, took any action or failed to expend amounts such that the Minister was entitled, pursuant to subsection (4), to revoke its registration as a private foundation. ... Accordingly, the commercial activity has a very close connection with the charity. ...
FCA
Shell Canada Resources Ltd. v. MNR, 84 DTC 6129, [1984] CTC 169 (FCA)
The duty of the Court is, in my opinion, in all cases the same, whether the Act to be construed relates to taxation or to any other subject, namely to give effect to the intention of the Legislature as that intention is to be gathered from the language employed having regard to the context in connection with which it is employed. ... In this connection it relies upon the well-known maxim of statutory interpretation expressio unius est exclusio alterius. ...
FCA
Timmins v. R., 99 DTC 5494, [1999] 2 CTC 133 (FCA)
The appellant performed his duties in connection with a contract made between the province, as executing agency, and the Canadian International Development Agency (“CIDA”), an agency of the Government of Canada’s Department of External Affairs. ... (a) was employed by a person who was a specified employer, and (b) performed all or substantially all the duties of his employment in one or more countries other than Canada (i) in connection with a contract under which the specified employer carried on business in such country or countries with respect to (A) the exploration for, or exploitation of, petroleum, natural gas, minerals or other similar resources. ...
FCA
Mandel v. The Queen, 78 DTC 6518, [1978] CTC 780 (FCA), briefly aff'd 80 DTC 6148, [1980] CTC 130, [1980] 1 S.C.R. 318
An Agreement dated February 1, 1973 between Canadian Film Development Corporation, Amaho Limited referred to as the assignee, Topaz Productions Limited, Niagara Television Limited, Robert Lawrence Productions Limited, John T Ross, and One Flag Under Ontario Investments Limited & Film Associates and Alexis Kanner sets out that Niagara provided financing of the film in the amount of $125,000 and paid a further sum of approximately $10,000 in connection with the completion of it. lt assigns all its rights save for the $10,000 to Amaho Limited, the assignee, and in consideration of $1 the Canadian Film Development Corporation assigns any interest which it had to recoupment of monies advanced by it out of a share of the profits the film made and the parties release the corporation from any demands or claims for the balance of its $250,000 commitment which it had not yet paid ($3,420). ... He said at 247 to 249: No doubt the words “liability” and “contingent liability” are more often used in connection with obligations airsing from contract than with statutory obligations. ...
FCA
The Queen v. Cork, 90 DTC 6358, [1990] 2 CTC 116 (FCA)
This room was used by him for preparing the invoices, updating his résumé, typing letters to prospective employers and making calculations and preparing sketches in connection with the then current engagement. ... All his professional services were rendered in one particular civic hospital and all the administrative work in connection with his practice was conducted in his home. ...
FCA
Canada v. Duguay, docket A-756-98
Levert pleaded guilty in connection with the instant cases to charges of conspiracy to avoid tax and enabling tax of $110,000 to be avoided by taxpayers, including the respondents, for the 1986 to 1988 taxation years. ... A probation order for two years was also made against him, prohibiting him from acting directly or indirectly as an appraiser, promoter, broker or consultant in connection with gifts of art works to non-profit organizations. [5] For 1986 to 1989, Mr. and Mrs. ...
FCA
Intermodal Container Transport Ltée v. Beauchamp, docket ITA-1716-98
Given this tax debt, Revenu Québec had seized the cranes from Crane. [46] These cranes among the seized property are the following: 2.1 Ford 9000 truck, orange NS/ W9OJVHA6973 with boom, registration L86164; 3.1 Grove crane, model 4080 NS/ R21365, registration FN98335; [47] There are two paradoxes in connection with these cranes. [48] First, these cranes are covered in contract D.1, which we reviewed earlier. ... However, it covers two distinct properties, namely: 6.1 Pontiac Transport vehicle, green, registration FM12051, NS/1GMDU06D2RT213152; 7.1 Jaguar vehicle, grey, without engine, registration FE96635; [51] There is also a paradox in connection with this latter contract. ...
FCA
Canada v. Munro, docket A-570-97
Munro was: [...] entitled to be reimbursed any expenses she may have incurred in connection with her appeals. ... ] [15] One must start from the premise that Garon J. was purporting to act within his authority under the Act when he made an order for "reimburse[ment] of any expenses she may have incurred in connection with her appeals". ...
FCA
Canada v. 3850625 Canada Inc., 2011 FCA 117
[11] T he Tax Court Judge went on to consider whether there was a sufficient connection between the refund and the production and processing activities. ... In particular, she relied on these decisions to dispose of the Crown’s argument that there was not a sufficient connection between income tax and production and processing activities because income tax is paid after these activities are completed (reasons at para. 25). ...
FCA
St-Fort v. Canada, 2009 FCA 188
They were also respondents in the appearance filed in the Superior Court in connection with the continuance of suit: ibid. at tab 16. ... That explains the appearance filed in connection with the continuance of suit, the filing for a rehearing of the motion for forced surrender and for taking in payment and the judgment dated June 27, 1997, granting the appellants (who were the applicants in the continuance of suit) ownership of the immovable. ...