Search - connection
Results 341 - 350 of 532 for connection
FCA
Mobil Oil Canada Ltd. v. Canada, 2001 DTC 5668, 2001 FCA 333
In the context of payments to a province, the word "royalty" may describe any share of resource production that is paid to the province in connection with its interest in the resource. [22] Under the Road Allowances Crown Oil Act, Mobil had the right to sell its entire oil production for the years under appeal, including the Province's 1.88% share, upon paying the Province an amount equal to 1% of the total value of the production. ...
FCA
Transcanada Pipelines Ltd. v. The Queen, 2001 DTC 5626, 2001 FCA 314
TCPL hoped to avoid the time and money of TCPL, the Minister and Tax Court in connection with what might well be unnecessary litigation. [5] Neither individually, nor collectively, do these reasons establish any practical necessity for not including in the notice of appeal all the issues upon which TCPL intended to rely. ...
FCA
Harvey C. Smith Drugs Ltd. v. The Queen, [1995] 1 C.T.C. 143 (FCA)
We note, however, that the opening words of that definition indicate that the term applies to those activities "when they are performed in Canada in connection with manufacturing or processing... ...
FCA
Perini Estate v. The Queen, 82 DTC 6080, [1982] CTC 74 (FCA)
Thurlow, J added the following observations at 78 [423, 1238], which counsel for the appellant found particularly helpful to his contention: In this connection, it may be noted that, while the House of Lords in Riches v Westminster Bank [[1947] 1 All ER 469] overruled Re National Bank of Wales [[1899] 2 Ch 629], it did not overrule Commissioner of Inland Revenue v Ballantine [(1921) 8 TC 595] or Simpson v Executors of Bonner Maurice [(1920) 14 TC 580] both of which appear to me to be stronger cases in this respect than the present for attributing an income nature to the sums in question, since in these cases the taxpayer’s right to the sum to which “interest” was added arose prior to or at the commencement of the period in respect to which the “interest” was computed. ...
FCA
Schroter v. Canada, 2010 DTC 5062, 2010 FCA 98
The paragraph was held to take into income a material acquisition which conferred an economic benefit, so long as the acquisition did not fall within one of the exceptions, and so long as the acquisition was received in connection with employment ...
FCA
The Queen v. Optical Recording Laboratories Inc., 90 DTC 6647, [1990] 2 CTC 524 (FCA)
On the contrary, their whole case was that they had made a sensible arrangement in the overall performance of their statutory duties in connection with taxes management, an arrangement made in the best interests of everyone directly involved and, indeed, of persons indirectly involved, such as other taxpayers, for the agreement reached would be likely to lead ultimately to a greater collection of revenue than if the agreement had not been reached or "amnesty" granted. ...
FCA
Canada v. JES Investments Ltd., 2007 DTC 5608, 2007 FCA 337
Moreover, after the payment of the subscription price of the Shares, the only meaningful connection of the taxpayer to Deena was by virtue of the taxpayer’s holding and ownership of the Shares. ...
FCA
Orly Automobiles Inc. v. Canada, 2005 FCA 425
Auto without knowing who they were, whether they were incorporated, whether there was a connection between it and 2844 Québec Inc., whether P.G. ...
FCA
F.K. Clayton Group Ltd. v. MNR, 88 DTC 6202, [1988] 1 CTC 353 (FCA)
At the time of the events here in issue, however, they read as follows: 231. (1) Any person thereunto authorized by the Minister, for any purpose related to the administration or enforcement of this Act, may, at all reasonable times, enter into any premises or place where any business is carried on or any property is kept or anything is done in connection with any business or any books or records are or should be kept, and (a) audit or examine the books and records and any account, voucher, letter, telegram or other document which relates or may relate to the information that is or should be in the books or records or the amount of tax payable under this Act, (b) examine property described by an inventory or any property, process or matter an examination of which may, in his opinion, assist him in determining the accuracy of an inventory or in ascertaining the information that is or should be in the books or records or the amount of any tax payable under this Act, (c) require the owner or manager of the property or business and any other person on the premises or place to give him all reasonable assistance with his audit or examination and to answer all proper questions relating to the audit or examination either orally or, if he so requires, in writing, on oath or by statutory declaration and, for that purpose, require the owner or manager to attend at the premises or place with him, and (d) if, during the course of an audit or examination, it appears to him that there has been a violation of this Act or a regulation, seize and take away any of the documents, books, records, papers or things that may be required as evidence as to the violation of any provision of this Act or a regulation. (2) The Minister shall, (a) within 120 days from the date of seizure of any documents, books, records, papers or things pursuant to paragraph (1)(d), or (b) if within that time an application is made under this subsection that is, after the expiration of that time, rejected, then forthwith upon the disposition of the application, return the documents, books, records, papers or things to the person from whom they were seized unless a judge of a superior court or county court, on application made by or on behalf of the Minister, supported by evidence on oath establishing that the Minister has reasonable and probable grounds to believe that there has been a violation of this Act or a regulation and that the seized documents, books, records, papers or things are or may be required as evidence in relation thereto, orders that they be retained by the Minister until they are produced in any court proceedings, which order the judge is hereby empowered to give on ex parte application. ...
FCA
Elias Rogers Co Ltd. v. MNR, 73 DTC 5030, [1972] CTC 601 (FCTD)
The sole question involved in this appeal is the question whether one element of the expenses incurred by the appellant in connection with the leasing of water heaters was an expense of earning income that was deductible in computing its annual profit from the business notwithstanding paragraph 12(1)(b) of the Income Tax Act, which reads as follows: 12. (1) In computing income, no deduction shall be made in respect of (b) an outlay, loss or replacement of capital, a payment on account of capital or an allowance in respect of depreciation, obsolescence or depletion except as expressly permitted by this Part, Each of the water heaters cost the appellant $197. ...