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Results 351 - 360 of 535 for connection
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. ...
FCA

Nova Construction Co. Ltd. v. The Queen, 85 DTC 5594, [1986] 1 CTC 68 (FCA)

During the 1975 taxation year the blackmobile was used in connection with a number of construction projects carried out by the respondent on the mainland side of the Canso Causeway — at Antigonish, Mulgrave, Cape George and on the old Antigonish Road leading to the Strait of Canso — as well it was on the Cape Breton side between Port Hastings and Port Haw- kesbury and at Port Malcolm. ...
FCA

Coca Cola Ltd. v. Dep. MNR, 84 DTC 6081, [1984] CTC 75 (FCA)

While the added paragraph (f), unlike the preceding paragraphs, further expands the definition by reference to functions carried out in connection with goods, it does not, in my opinion, give rise to an inference that such functions necessarily constitute “manufacture or production” or “manufacturing or producing” within the meaning of any of the provisions of the Act. ...
FCA

The Queen v. Jennings, 94 DTC 6507, [1994] 2 CTC 106 (FCA)

While the added paragraph (f), unlike the preceding paragraphs, further expands the definition by reference to functions carried out in connection with goods, it does not, in my opinion, give rise to an inference that such functions necessarily constitute “manufacture or production” or “manufacturing or producing" within the meaning of any of the provisions of the Act. ...
FCA

Industries Perron Inc. v. Canada, 2013 FCA 176

Specifically, the Tax Court Judge asked himself whether the amount in issue was non-deductible because it was paid in connection with a reserve, a contingent liability or a sinking fund, contrary to paragraph 18(1)(e) or whether the deduction was permitted pursuant to paragraph 20(1)(vv) of the Act as an amount paid in respect of an existing or proposed countervailing or anti-dumping duty ...
FCA

Great-West Life Assurance Company v. Canada, 2016 FCA 316

E-15 (Act) on fees for services provided in connection with group health benefit plans it offers to employers. [2]                Great-West appealed the assessments to the Tax Court of Canada on the basis that the fees were paid for a financial service, which would be an exempt supply. [3]                In the Tax Court (2015 TCC 225), Justice Owen (judge) concluded that the fees were subject to tax because they were paid for an administrative service which generally falls outside the definition of “financial service.” ...
FCA

Canada v. J. Hudon Enterprises Ltd., 2010 FCA 37

The Company shall, as authorized by the Ontario Racing Commission Rule 18.11, withhold on behalf of all drivers competing at Hiawatha Horse Park five (5) percent of all purse money won by horses driven by each driver.Said withholding and any expenses in connection therewith shall be borne by the Company at the Company’s expense.All sums payable under this Article shall be paid once a month ...
FCA

Smith v. Canada, 2001 FCA 86, 2001 FCA 84

Generally, a person who is experienced in business and financial matters is likely to be held to a higher standard than a person with no business acumen or experience whose presence on the board of directors reflects nothing more, for example, than a family connection. ...
FCA

Canada v. 158377 Canada Inc., docket ITA-4127-95

Deschênes (Court of Quebec, case 200-02-016759-971, October 17, 1997, Judge Bond) and the case law cited therein, the Paulian action may be relied on to challenge an objection to his seizure and accordingly a creditor may thus act and execute without first obtaining a court ruling that the act may not be set up against him;                 WHEREAS finally the written submissions of the judgment creditor filed on October 1 and October 14, 1999 persuade the Court that all the conditions for the Paulian action have been met;                 WHEREAS further the objector cannot claim damages in this Court in connection with a motion;                 In view of the foregoing, the objection to the seizure by the Société en commandite Notre Dame du Bon Conseil must be dismissed with costs. [3]         The relevant facts may be summarized as follows: 158377 Canada Inc. became a debtor of the creditor in the amount of $36,255.32 for failing to pay its taxes. ...

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