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Results 381 - 390 of 532 for connection
FCA

Harwill Investment Corp. v. R., [1999] 2 CTC 342, 99 DTC 5207

Moreover, while the undesirable effects of traffic congestion on the popularity of the shopping centre and on its prospects for competing with a rival shopping centre might conceivably have led to some other whole or partial solution involving an outlay of a capital nature, such as to restructure the shopping centre or its buildings or its means of access, and ress and some such outlays may indeed have been made), this is 0t whal t expimditure here in es on was for The mane ’ was not cid or change in 0r additions to the la' li " ULeilk. ises or the buildings thereon or in connection with the structure s of the plaintiff's business^ Rather, it was paid to induce the City to make changes on City property that could be beneficial to the plaintiff in achieving its object of promoting its business by enhancing the popularity of its shopping centre. [13] *[emphasis added] Here, the exchange of land and the payment for the relocation of Pierre Corneille Street are not severable. ...
FCA

Berenguer v. Sata Internacional - Azores Airlines, S.A., 2021 FCA 217

Respondent REASONS FOR ORDER MONAGHAN J.A. [1] The appellant has brought two motions in connection with her appeal of the Federal Court’s order in Berenguer v. ...
FCA

Wood v. Canada, 2022 FCA 60

While he had an explanation—the police seized the books and records in connection with the criminal investigation and did not return them—that did not relieve Mr. ...
FCA

Soulliere v. Canada, 2022 FCA 126

These provisions state: 124 (1) Despite subsection 126 (6), but subject to subsections (2), (4) and (5) of this section, a quorum of directors may fill a vacancy among the directors, except a vacancy resulting from, 124 (1) Malgré le paragraphe 126 (6), mais sous réserve des paragraphes (2), (4) et (5) du présent article, les administrateurs peuvent, s’il y a quorum, combler les vacances survenues au sein du conseil d’administration, sauf celles qui résultent: (a) an increase in the number of directors otherwise than in accordance with subsection (2), or in the maximum number of directors, as the case may be; or a) soit d’une augmentation du nombre fixe d’administrateurs autrement qu’aux termes du paragraphe (2), ou du nombre maximal d’administrateurs, selon le cas; (b) a failure to elect the number of directors required to be elected at any meeting of shareholders. b) soit du défaut d’élire le nombre d’administrateurs à élire à une assemblée d’actionnaires.   186 (3) Where a reorganization is made, the court making the order may also, (3) Dans le cadre d’une réorganisation, le tribunal qui rend l’ordonnance peut également: … […] (b) appoint directors in place of or in addition to all or any of the directors then in office. b) nommer d’autres administrateurs ou remplacer ceux qui sont en fonction.   248 (3) In connection with an application under this section, the court may make any interim or final order it thinks fit including, without limiting the generality of the foregoing, 248 (3) Le tribunal peut, dans le cadre d’une requête visée au présent article, rendre l’ordonnance provisoire ou définitive qu’il estime opportune pour, notamment: … […] (e) an order appointing directors in place of or in addition to all or any of the directors then in office; e) faire des nominations au conseil d’administration, soit pour remplacer tous les administrateurs en fonction ou certains d’entre eux, soit pour en augmenter le nombre   [20] The foregoing provisions regarding the appointment or election of directors all require deliberate acts. ...
FCA

Cam Gard Supply Limited v. Minister of National Revenue, [1974] CTC 487, 74 DTC 6429

In this connection it was contended that had the appellant an hour before making the payment exercised its right under Article IX of the trust agreement to amend the plan by changing the wording of sections IX and X thereof so as to impose enforceable obligations on the appellant to make the payment and on the trustees to purchase past service pensions, the payment subsequently made would have qualified for deduction. ...
FCA

Northbridge Commercial Insurance Corporation v. Canada, 2023 FCA 211

The supply of a financial service is an exempt supply for the purposes of the ETA, unless it is included in Part IX of Schedule VI (section 1 of Part VII of Schedule V). [16] No GST is collectible in relation to exempt supplies (section 165 of the ETA and the definitions of taxable supply and commercial activity in subsection 123(1) of the ETA) and no ITCs can be claimed for any GST paid on any goods or services acquired in connection with the making of exempt supplies (section 169 of the ETA and the definition of commercial activity in subsection 123(1) of the ETA). [17] Part IX of Schedule VI provides that certain supplies of financial services will be zero-rated supplies. ...
FCA

Potash Corporation of Saskatchewan Inc. v. Canada, 2024 FCA 35

There is a direct and immediate connection between the production of potash and the subsequent sale or disposition of that potash. ...
FCA

Pollock (J.A.) v. Canada, [1994] 2 CTC 385

The failure to properly understand and apply the law as it applies to capital gains in share transactions The appellant's submission in this connection starts from the proposition that the acquisition of shares is "presumptively an investment". ...
FCA

Hud v. Canada, 2024 FCA 82

T‑2. [7] Before the Tax Court, the appellant’s principal allegation was that he was unable to file his tax returns for 2017 to 2019, despite the Minister’s request, because in 2017 his home, containing his tax records, was seized in connection with unrelated matters. ...
FCA

Tonn v. The Queen, [1996] 1 CTC 205 (FCA)

. — “personal or living expenses” includes (a) the expenses of properties maintained by any person for the use or benefit of the taxpayer or any person connected with the taxpayer by blood relationship, marriage or adoption, and not maintained in connection with a business carried on for profit with a reasonable expectation of profit,... ... McDonnell as follows: The expression [reasonable expectation of profit] is found in the Income Tax Act in the extended definition of personal or living expenses, which includes the phrase “the expenses of properties...not maintained in connection with a business carried on with a reasonable expectation of profit”. ...

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