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Results 361 - 370 of 535 for connection
FCA

Canada v. Marcoux-Côté, docket A-758-98

A probation order was also made prohibiting him from acting directly or indirectly as an appraiser, promoter, broker or consultant in connection with gifts of works of art to non-profit organizations, for a period of two years. ...
FCA

Canada v. Furukawa, docket A-80-99

The same is true of the letter's description of the "current status" of the interest in the Grassy pipeline to which unit holders were entitled: there is no indication that the connection to the Husky pipeline had occurred or was imminent in May 1991. ...
FCA

Mangat v. Canada, docket A-59-98

I note that in oral argument, counsel for the Applicant did not take issue with the findings of the Tax Court Judge concerning connection between the Applicants and the taxi drivers under the lease arrangement. [16]      It is not necessary for the Applicants to control all aspects of the hiring process in order to employ a person as a driver of a taxi. ...
FCA

Simard v. Canada, 2009 FCA 379

An assessment shall not be vacated or varied on appeal by reason only of any irregularity, informality, omission or error on the part of any person in the observation of any directory provision of this Act.       237.1 (1) “Definitions” – In this section,   “tax shelter” means any property in respect of which it may reasonably be considered having regard to statements or representations made or proposed to be made in connection with the property that, if a person were to acquire an interest in the property, at the end of any particular taxation year ending within 4 years after the day on which the interest is acquired,   (a) the aggregate of all amounts each of which is (i) a loss represented to be deductible in computing income in respect of the interest in the property and expected to be incurred by or allocated to the person for the particular year or any preceding taxation year, or (ii) any other amount represented to be deductible in computing income or taxable income in respect of the interest in the property and expected to be incurred by or allocated to the person for the particular year, other than any amount included in computing a loss described in subparagraph (i), would exceed (b) the amount, if any, by which (i) the cost to the person of the interest in the property at the end of the particular year, would exceed (ii) the aggregate of all amounts each of which is the amount of any prescribed benefit that is expected to be received or enjoyed directly or indirectly in respect of the interest in the property, by the person or a person with whom the person does not deal at arm’s length but does not include property that is a flow-through share or a prescribed property.     248. (1) “Specified member” of a partnership in a fiscal period or taxation year of the partnership, as the case may be, means   (a) any member of the partnership who is a limited partner (within the meaning assigned by subsection 96(2.4)) of the partnership at any time in the period or year, and   (b) any member of the partnership, other than a member who is (i) actively engaged in those activities of the partnership business which are other than the financing of the partnership business, or (ii) carrying on a similar business as that carried on by the partnership in its taxation year, otherwise than as a member of a partnership, on a regular, continuous and substantial basis throughout that part of the period or year during which the business of the partnership is ordinarily carried on and during which he is a member of the partnership;   151. ...
FCA

Bouchard v. Canada (Attorney General), 2009 FCA 321

.), whose full title is An Act respecting pension plans organized and administered for the benefit of persons employed in connection with certain federal works, undertakings and businesses. ...
FCA

OLTCPI Inc. v. Canada (National Revenue), 2010 FCA 74

The bulk purchasing service has no connection with the supply of dieticians. ...
FCA

Saskferco Products ULC v. Canada, 2008 FCA 297

It is conceded that subsection 39(2), which deems foreign exchange losses to be on capital account, only applies if the underlying transaction in connection with which the losses were incurred is capital in nature: Imperial Oil Ltd. v. ...
FCA

SMX Shopping Centre Ltd. v. Canada, 2003 FCA 479

SMX claimed that the joint venture failed in 1994 because of poor market conditions, resulting in a loss to SMX of $1,180,542. [5]                 SMX, in filing its income tax returns for 1993 and 1994, claimed deductions for management fees paid to Amir Malekyazdi, in the amount of $85,500 in 1993 and $42,500 in 1994, for services rendered in connection with the Golbanoo joint venture. ...
FCA

Nadeau v. Canada (Minister of National Revenue), 2003 FCA 400

This decision could have had a significant impact on the deduction that support recipients could claim under paragraph 18(1)(a), since paragraph 18(1)(c) stipulates that no expense may be deducted "in connection with property the income from which would be exempt". [33]       To maintain the right to the deduction, Parliament amended the definition of "exempt income" in subsection 248(1) to exclude the part of the support that is intended for children, even if it is now non-taxable. ...
FCA

Earth Fund v. Canada (Minister of National Revenue), 2002 FCA 498

He also held that even if the collection of used goods could be said to be a business, it would be a "related business" because of the close connection between the activity and the charitable objects of Alberta Institute, and because the funds raised by the activity were entirely dedicated to those charitable objects. [30]            I do not accept the argument of counsel for the appellant that the Alberta Institute case is authority for the proposition that any business is a "related business" of a charitable foundation if all of the profits of the business are dedicated to the foundation's charitable objects. ...

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