Search - connection

The applicant argues that his brothers were targeted by criminals and that there is indeed a connection between his risk of persecution or mistreatment and the disappearance of one of his brothers and the death of another. [14]   Having reviewed the file, the Court cannot accept the applicant’s argument. ... The evidence in the record was also a sufficient basis for the RAD’s finding that the applicant had failed to establish a connection between his personal circumstances, the death of one of his brothers and the safe haven. [15]   The applicant also criticizes the RAD for finding that he would be able to work in the safe haven on the basis of the fact that he had been able to work when he was in the United States. ...

The existence of zoning by-laws which legally oblige a taxpayer to have a minimum amount of land in connection with her residence, is not sufficient, in and of itself, to discharge the critical burden of proof on the plaintiff for the purposes of paragraph 54(g) of the Income Tax Act. ... My understanding of the principle in Yates is that the minimum amount of land which the taxpayer is legally obliged to have in connection with his residence at the time of disposition of the property establishes objectively the amount of land associated with the principal residence”. ...

The plaintiff alleged that it was entitled to interest on this amount on the ground that the case at bar is subject, not only to the applicable federal statutes, but also the statutes of the province of Quebec, since the airplane was bought in connection with the development project at James Bay, Quebec. ... In that case, where the Crown was held liable in damages in connection with a lease of a golf club in British Columbia, the judge dismissed the claim relating to interest under the provisions of the aforesaid section 35. ...

Moving expenses, as permitted by ss 62(3), do not, as I see it, mean outlays or costs incurred in connection with the acquisition of the new residence. ... While the subject matter of the deductions sought in the Storrow case are entirely different from those here: costs incurred in connection with the acquisition of the new residence, rather than damage incurred in transit, the principle is the same. ...

It is therefore admitted that during the years 1964, 1965 and 1966, the appellant was the co-owner of a very successful race horse known as George Royal and that the various amounts (as varied by the agreement made at the trial) added by the respondent to the appellant’s declared income for the years under consideration represent the appellant’s share of the prize money won by George Royal after deduction of the legitimate expenditures made in connection with the racing of this horse. ... The appellant did not keep detailed and complete records of the expenses made in connection with his racing activities. ...

The effect of such a designation would have been to provide Wellesley with the full municipal rebate of Goods and Services Tax and Harmonized Sales Tax (GST/HST) in connection with its supply of housing ... In July 2008 Wellesley entered into two agreements with the City of Toronto in connection with the Residences.   ... Accordingly, Wellesley ’s activities in connection with the Residences are not qualifying activities for purposes of municipal designation.   ...

The defendant urges me to infer, from the description of Stone Manor as “inventory", from the plaintiff's connection with corporations trading in horses and from the speculative or high-risk nature of the purchase of race horses, that the plaintiff had, from the outset, a secondary intention of turning his horse to profit. ... It has not been demonstrated to my satisfaction that the plaintiff's connection with corporations trading in horses (mostly quarter horses) coloured his personal acquisition of a racing thoroughbred so as to make the notion of secondary intention applicable in this case. A taxpayer's connection with real estate buying and selling operations has not led to the conclusion in other cases that the gain from the sale of property must be viewed as income: Racine v MNR, supra, in translation at DTC 5104 and in the original French text at 161 (DTC 5113); and, Bead Realties v MNR, supra, at 776 (DTC 5454). ...

The absence of any connection between the two sources of income therefore precludes any consideration of them in combination. ... Prior to my analysis of the issues, I will deal with the plaintiff’s argument that a connection between the taxpayer’s various sources of income is required in a combination case before the taxpayer may be considered to be a Class I farmer. The plaintiff contends that the investment in the farm operation of income from a subsidiary business is insufficient to establish a connection between the two revenue sources. ...

Paragraph (b) of Regulation 5202 reads as follows: (b) all other activities that are performed in Canada directly in connection with manufacturing or processing (not including the activities listed in subparagraphs 125.1 (3)(b)(i) to (ix) of the Act) in Canada of goods for sale or lease,... ... The court could not find on the particular facts of the case that the service aspect of the taxpayer's business activity was more important than the production of the specialized product required in connection therewith. ... Moreover, it is not without significance, in my view, that the definition of “qualified activities’ in paragraph (b) of Regulation 5202 makes specific reference to activities performed in Canada “directly in connection with manufacturing or processing... in Canada of goods for sale or lease” (My italics). ...

This is evident from the various dictionary definitions of the word “Royalty” when used in connection with a sum payable. ... 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. ...