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Results 131 - 140 of 1090 for connection
FCTD
Sherway Centre Ltd. v. R., [1998] 2 C.T.C. 343, (sub nom. R. v. Sherway Centre Ltd.) 98 D.T.C. 6121
The participatory interest payments can be characterized as a cost of borrowing money or as being made for the use of borrowed money because they are “in connection with,” “incidental to,” or “arising from” the borrowing. ... While Thurlow J. does state in his decision in Yonge-Eglinton that the payments “refer to the process of carrying out or the things which must be undertaken to carry out the issuing or selling or borrowing for or in connection with which the expenses are incurred,” nonetheless, I do not read this section of his judgment as limiting the participating interest payments at issue here. ... It may not always be easy to decide whether an expense has so arisen but it seems to me that the words ‘in the course of’ in paragraph 11(1)(cb) are not a reference to the time when the expenses are incurred but are used in the sense of ‘in connection with’ or ‘incidental to’ or ‘arising from’ and refer to the process of carrying out or the things which must be undertaken to carry out the issuing or selling or borrowing for or in connection with which the expenses are incurred. 19 Lacroix J. in his concurring opinion also found at page 216: This is the cost or the price the taxpayer had to pay, or in the words of the statute (11(1)(cb) this is the expense he had to incur or the financial burden he had to assume, in order to obtain the needed money for the purpose of earning income from a business or property. ...
FCTD
The Queen v. Lavers, 78 D.T.C 6230, [1978] CTC 341 (FCTD)
In addition, the Association proposes that such employees be paid a further 9 cents per mile for all miles driven in connection with employment. ... Employees in such classes shall have the option of accepting the mileage allowance as outlined herein, or in lieu thereof, may accept. a monthly car allowance of $80.00 plus a mileage allowance of nine cents per mile for all miles driven in connection with employment. ... However, the incontrovertible fact remains that nowhere in this defendant’s income tax return is there any computation of an allowance arrived at by reference to time actually spent by him in travelling away from his office in connection with his employer’s work. ...
FCTD
eBay Canada Limited v. Canada (National Revenue), 2007 DTC 5573, 2007 FC 930
The Zundel case was [page456] decided on grounds related to the provisions of the Canadian Human Rights Act, but for present purposes the object lesson of those facts is nevertheless instructive. 60 The "real and substantial connection" test was adopted and developed by this Court in Morguard Investments, supra, at pp. 1108-9; Hunt v. ... From the outset, the real and substantial connection test has been viewed as an appropriate way to "prevent overreaching... and [to restrict] the exercise of jurisdiction over extraterritorial and transnational transactions" (La Forest J. in Tolofson, supra, at p. 1049). ... C.A.); Re World Stock Exchange (2000), 9 A.S.C.S. 658. 63 Generally speaking, this Court has recognized, as a sufficient "connection" for taking jurisdiction, situations where Canada is the country of transmission (Libman, supra) or the country of reception (Liberty Net, supra). ...
FCTD
Hale v. The Queen, 90 DTC 6481, [1990] 2 CTC 247 (FCTD), aff'd 92 DTC 6473 (FCA)
In this regard the plaintiff analyzed Articles 7 and 15 of the Convention and came to the conclusion that the reason the legislature included a past condition in Article 7 of the Convention was that it intended that only "wages, salaries, and other similar remuneration" received in connection with employment actually held in Canada during the relevant taxation year should be covered by this article. ... As he in fact spent 57 days in Canada in 1984 in connection with these duties as director, the plaintiff maintained that only the portion representing /366ths of $25,000 is taxable in Canada, in accordance with subparagraph 115(1)(a)(v) and clause (2)(e)(i)(B) of the Income Tax Act. ... The question that must now be answered in connection with the first point at issue is as follows: is the sum of $125,212.50 from the realization of share purchase option rights "salaries, wages and other remuneration" within the meaning of Article 15(1)of the Canada-United Kingdom Income Tax Convention or a benefit within the meaning of paragraph 7(1)(b) of the Income Tax Act? ...
FCTD
Gregory v. MNR, 92 DTC 6518, [1992] 2 CTC 250 (FCTD)
("Geddes") and others in connection with the acquisition of interests in a partnership carrying on business under the firm name of Grand Bell Property Ltd. ... ("Geddes") and other in connection with the acquisition of interests in a partnership carrying on business under the firm name of Grand Bell Property, Ltd. 3. ... Annexed as exhibit "A" to this my affidavit is a summary of the documents in respect of which I have claimed privilege on behalf of Geddes and all of the other partners for whom I have served as solicitor in connection with the transactions pertaining to the partnership. 3. ...
FCTD
Kimberly-Clark Canada Inc. v. Canada, docket T-2975-94
Toilet paper can be defined as a "good..intended for use...in connection with the care of the human body...for cleansing". ... Although the use of facial tissues for dealing with the symptoms of a cold is not part of one"s normal, daily routine, the use of facial tissue "...in connection with the care of the human body...for cleansing (such as make-up removal)" is sufficient to bring it within the definition of toilet article. ... On this basis, although such use is not exclusive, it is clear that facial tissue can be described as an article which is "...commonly known as a toilet article...in connection with the care of the human body". [35] For these reasons, judgment shall be in favour of the plaintiff. ...
FCTD
HomeAway.com, Inc. v. Hrdlicka, 2012 FC 1467
The Zundel case was [page456] decided on grounds related to the provisions of the Canadian Human Rights Act, but for present purposes the object lesson of those facts is nevertheless instructive. 60 The "real and substantial connection" test was adopted and developed by this Court in Morguard Investments, supra, at pp. 1108-9; Hunt v. ... From the outset, the real and substantial connection test has been viewed as an appropriate way to "prevent overreaching... and [to restrict] the exercise of jurisdiction over extraterritorial and transnational transactions" (La Forest J. in Tolofson, supra, at p. 1049). ... C.A.); Re World Stock Exchange (2000), 9 A.S.C.S. 658. 63 Generally speaking, this Court has recognized, as a sufficient "connection" for taking jurisdiction, situations where Canada is the country of transmission (Libman, supra) or the country of reception (Liberty Net, supra). ...
FCTD
St-Laurent v. Canada (Attorney General), 2017 FC 776
The RCMP also pointed out that it considered the information in connection with FINTRAC to be relevant and reliable due to their nature and source. [17] On December 7, 2015, Mr. ... Without the documents enclosed with the report, the Court cannot know which corporations were targeted, the connections between them, the role and involvement of Mr. ... The applicants were unable to make the connection between these numbers and the tables filed in the Court record. [43] The applicants maintain that Corporal Harrisson’s report erroneously indicates that Mr. ...
FCTD
Kimberly-Clark Canada Inc. v. R., [1998] 3 CTC 88
Toilet paper can be defined as a “good..intended for use...in connection with the care of the human body...for cleansing”. ... Although the use of facial tissues for dealing with the symptoms of a cold is not part of one’s normal, daily routine, the use of facial tissue “...in connection with the care of the human body...for cleansing (such as make-up removal)” is sufficient to bring it within the definition of toilet article. ... On this basis, although such use is not exclusive, it is clear that facial tissue can be described as an article which is “...commonly known as a toilet article...in connection with the care of the human body”. ...
FCTD
John Page and Genevieve McLvers, Co-Executors of the Estate of Abe Levine (Deceased) v. Minister of National Revenue, [1973] CTC 219
In the latter part of 1964 or the early part of 1965 Mr E J Mockler, a barrister, was retained to do, in connection with Mr Levine’s affairs, what Mr Mockler called ‘overall planning”. ... In connection with the first of these points Mr Mockler submitted that the respondent assumed that there had been a transfer from Abe Levine to Weldon Levine and, in his submission, there was no such transfer. ... In this connection counsel for the appellants attempted to distinguish the Dufresne case on the ground, among others, that the Dufresne case was decided on an interpretation of subsection 137(2) of the Income Tax Act and that under the circumstances of this case that provision is not available to the respondent. ...