Search - connection

They import such meanings as "in relation to", "with reference to" or "in connection with". The phrase "in respect of" is probably the widest of any expression intended to convey some connection between two related subject matters. [11]            I also note that the result in this case is consistent with the result reached by the Tax Court in a previous case, involving payments for non-economic loss made to a worker under the Ontario workers’ compensation legislation: Larouche v. ...

Each of the mining companies had a mining project it hoped to develop. [2] While each MOU contemplated that the appellant would be engaged to provide services in connection with the development and later operation of the relevant mine, each also contained several other terms relevant to the ongoing relationship between the junior mining company and the appellant and its affiliates. [3] Neither project proceeded and, in 2013, the appellant sold the shares of both companies to a related corporation at a loss. ... It found the shares “were acquired and held …in connection with [the appellant’s] business”, “were not acquired for trading purposes”, and “constituted an investment …in the equity of the [mining companies]… intentionally [made]…with a view to further strategically enhancing its future growth, and recoveries/cash flow generated from its business.”: Reasons at paras. 1, 10. ...

Moreover, while no partnership had been formed, commencing in May, 1965, the trade name Central Park Management Company was used in connection with the apartment management operations and, in particular, the bank accounts used were in that name. ... Reichmann & Son Limited and Webb & Knapp (Canada) Limited in connection with the acquisition of Flemingdon Park. ... That the Agreement dated the 1st day of November, 1965 between the Company and Central Park Management Company hereinbefore referred to in connection with the management of the apartment buildings owned by the Company be and the same is hereby approved and the President and Treasurer of the Company be and they are hereby authorized to execute the aforementioned Agreement on behalf of the Company and to affix thereto the corporate seal of the Company. under that contract, the situation was the same, as among the parties, as though everything had been regularly done on November 1, 1965. ...

  [14]            Based on an analysis of the connecting factors, the judge found that there were indeed several connections between the investment income and the reserve. ... The substantive portion of the reasoning in this case was set forth by Justice Linden at paragraph 11: [11]      So too, where investment income is at issue, it must be viewed in relation to its connection to the Reserve, its benefit to the traditional Native way of life, the potential danger to the erosion of Native property and the extent to which it may be considered as being derived from economic mainstream activity. ... In such a context, the other connection factors are of little importance. ...

The context for the purpose of the interpretation of a treaty shall comprise, in addition to the text, including its preamble and annexes: (a) any agreement relating to the treaty which was made between all the parties in connexion with the conclusion of the treaty; (b) any instrument which was made by one or more parties in connexion with the conclusion of the treaty and accepted by the other parties as an instrument related to the treaty. 3. ... Article 31(2) of the Vienna Convention goes on to provide that the context is to include the text, preamble, annexes and any agreements or instruments made “in connexion with the conclusion of the treaty”. ... The argument, of course, is premised on the understanding that the Explanation is not a document made “in connexion with the conclusion of the treaty” as required under Article 31(2). ...

In my view, it cannot be said that the CITT failed to read the expression "attached to" in light of the preceding words and in harmony with the provision as a whole. [32]            Beyond this, there was evidence to support the CITT's conclusion that there was both a physical and a functional connection between the bags and the machines. ... According to the respondent, this definition covers a broader range of machinery than machinery for "filling" or "bagging". [36]            Whether one focuses on machinery that "packs", "fills" or "bags" onions, the CITT was of the view that the manual filling of the master bags resulted in there being an insufficient connection between the master bags and the machinery. In so holding, the CITT was addressing the extent of the connection that is required to bring an article within the tariff item. ...

The definition requires that statements or representations must be made, at some time, in connection with the property that is offered for sale. If no statements or representations have ever been made in connection with a property, then that property cannot constitute a tax shelter. Because the property that is contemplated by the definition of tax shelter is a property that is assumed to have been acquired by the prospective purchaser and the statements or representations are required to have been made in connection with that property, it follows that the statements or representations must have been made prior to any actual sale of the property that is offered for sale. ...

My view is not based on an attempt to trace a direct connection between each current expense incurred and the actual sales in the year. ... For the above reasons, I formed the opinion at the conclusion of argument for the appellant that the conclusion of the trial judge was correct and that the judgment of this Court should be that the appeal be dismissed with costs. subsections (3) and (10) of section 141 of the Act and sections 1204 and 1205 of these Regulations, (c) such part of any amount deducted in computing the taxpayer’s Income for the taxation year under paragraph (a) of subsection (1) of section 11 of the Act as, (i) in the case of a taxpayer whose principal business is contract drilling, may reasonably be regarded as having been deducted in respect of property acquired for the purpose of production of oil, gas, metals or industrial minerals, and (ii) in any other case, may reasonably be regarded as having been deducted in respect of property acquired for the purpose of exploring or searching for, or production of, oil, gas, metals or industrial minerals, to the extent that that part thereof has not already been deducted in computing profits for the purpose of subsection (2) or (3) or deducted under another paragraph of this subsection, (d) any amount deducted in computing the taxpayer’s income for the taxation year under paragraph (c) of subsection (1) of section 11 of the Act in respect of (i) borrowed money used in connection with, or used for the purpose of acquiring property used in connection with, or (ii) an amount payable for property used in connection with exploring or searching for, or production of, oil, gas, metals or industrial minerals, to the extent that the amount so deducted has not already been deducted in computing profits for the purpose of subsection (2) or (3) or deducted under another paragraph of this subsection, and (e) amounts not included in computing the taxpayer’s income for the year by virtue of subsection (5) or section 83 of the Act. 1 *Although all three questions put before the Trial Division were put forward in this Court, having regard to our conclusion, it was only necessary to hear counsel on one of them. 2 *1201. (4) For the purposes of subsections (2) and (3), there shall be deducted from the aggregate of the profits of a taxpayer for a taxation year reasonably attributable to the production of oil, gas, prime metal or industrial minerals from all of the resources operated by him, the aggregate of (a) his losses, if any, for the taxation year reasonably attributable to the pro duction of oil, gas, prime metal or industrial minerals from all the resources operated by him, (b) any amounts deducted in computing the taxpayer’s income for the taxa tion year under the provisions of paragraph (p) of subsection (1) of section 11 of the Act, section 83A of the Act, subsection (3) of section 85! ...

It is argued that the plaintiff's main activity is the provision of services and that the production of "goods" in connection therewith is only incidental to the service being provided. ... As counsel for the plaintiff pointed out, under such a regime, a manufacturer or processor of a product (eg: a chemical fertilizer) who also provided a service in connection therewith (eg: spreading the fertilizer for his customers) would be denied the processing tax deduction. ... The Customer at all times has complete charge, custody, control and responsibility for all tubing or other connections or equipment furnished for this receipt of delivery of the product for the well, the conditions within the well, the drilling or production pipe or other equipment about or in the well and the premises about the well. ...

Her textual analysis led her to conclude that there was no logical connection between paragraphs 6204(1)(b) and 6204(2)(c) such that the exception provided in the second paragraph would not allow for the requirements set out in the first to be disregarded (Reasons, para. 98). ... “For the purposes of subsection (1)” – the paragraphs in subsection 6204(2) will only apply to subsection 6204(1) if there is a logical connection (Reasons, para. 88). [38]            In her opinion, there is no logical connection between paragraphs 6204(1)(b) and 6204(2)(c). ... That said, she does not seem to have considered the logical connection between paragraph 6204(2)(c) and paragraph 6204(1)(b) through subparagraph 6204(1)(a)(iv), which connection is clear if, as the appellants claim, paragraph 6204(1)(b) is an anti-avoidance provision intended to ensure full compliance with subparagraph 6204(1)(a)(iv). [41]            On this point, the TCC judge recognized that paragraph 6204(1)(c) serves to prevent the avoidance of paragraph 6204(1)(a) by amending the terms and conditions of the shares during the two year period following their issuance. ...