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Results 141 - 150 of 1090 for connection
FCTD
Keevil Consultants Limited v. Minister of National Revenue, [1973] CTC 518, 73 DTC 5409
Geophysical actually billed the members of the syndicate at the rate of $40 a claim for 29 claims for a total of $1,160 distributed amongst them in accordance with their proportionate interest in same, despite the fact that their total expenses in connection with same was indicated on the ledger sheet headed Joe C Frantz amounted to $1,118.29. ... On the contrary, it is abundantly clear that he was at all times under the direction of Dr Keevil Senior and his business associates who had employed him for many years and this arrangement was by no means terminated or altered in connection with this specific project. ... The same question came before Chief Justice Jackett (then President) in connection with this same undertaking in the case of Jill E Kay v MNR, [1971] CTC 113; 71 DTC 5085, where it was held that the mining claims were not acquired pursuant to an arrangement with an employee or prospector and the appellant was not entitled to the exemption under subsection 83(3). ...
FCTD
Rosslynn Estates Limited v. Minister of National Revenue, [1972] CTC 65, 72 DTC 6051
In this connection, reference can i: made to the statement of Judson, J in Regal Heights Ltd v MNR, [196C SCR 902: [1960] CTC 384, in which, referring to the significance I the objects clauses set out in the company’s charter, he stated I page 907 [390]: Nothing turns upon such a statement in such a document. ... In 1944 his father was not well and needed help on the farm so he got permission to return to Oshawa to work with General Motors in connection with the design of military trucks, at the same time helping his father with the farm. ... While the company could properly include as fixed assets an office building which it was occupying in connection with the operation of its business, I am of the opinion that in view of the very wide powers given to it in its charter, any other properties acquired by it should be included in inventory and profits from the disposal of same taxed as regular business profits. ...
FCTD
Gary C. Graves and Mary J. Graves v. Her Majesty the Queen, [1990] 1 CTC 357
In connection with this business Mr. Graves reported income, expenses and resultant losses of $1,549 and $6,787 for 1978 and 1979 respectively. ... The type of deductions contemplated under paragraph 18(1)(a) of the Income Tax Act do not include expenses arising simply by virtue of casual connection to a business activity. ... In my view, in this case, the trips to the U.S. were made in connection with the business. ...
FCTD
The Queen v. Metropolitan Properties Co. Ltd., 85 DTC 5128, [1985] 1 CTC 169 (FCTD)
(emphasis mine) Defendant refers to another Tax Review Board case of Guaranteed Homes Limited v MNR, [1977] CTC 2287; 77 DTC 202, in which the taxpayer deducted the cost of utilities connections to 77 building lots in a subdivision as being attributable to his business premises. ... The taxpayer’s appeal was allowed however on the basis of the wording of paragraph 20(1)(ee) of the Act which permitted the cost of utilities connections to a taxpayer’s place of business to be deducted as an expense. ... The Board held that money spent for the purpose of making service connections was spent for the purpose of making the Appellant’s inventory of land more saleable and therefore entitled to deduct the amount spent for this purpose in the taxation year in question. ...
FCTD
Choice Realty Corp. v. The Queen, 78 DTC 6415, [1978] CTC 613 (FCTD)
However no sale to the city had taken place prior to 1976 and Place Versailles was still in communication with Quebec Hydro respecting the purchase of this property, until in September 1976 Quebec Hydro sold it to the city for parking in connection with a new metro station. ... Negotiations were then taken up with Toulon Construction and with Eastmere Investment Corporation and in 1967 they began to negotiate with Mr D Deskin an architect in connection with an emphyteutic lease for the apartment house land. ... Mr Gregory testified that no plans had ever been made after 1963 for the development of the apartment house land by plaintiffs themselves. but that they had been approached by other people in this connection and had always insisted on emphyteutic leases. ...
FCTD
Gibson Bros Industries Limited v. Minister of National Revenue, [1972] CTC 221, 72 DTC 6190
There are two distinct issues involved in the appeal, the first arising out of the manner in which appellant disposed of certain of its assets in connection with its Jeune Landing lumbering operations on Northern Vancouver Island, and the second with the manner in which it apportioned the expenses arising out of the operation of the vessel "Norsal" used by it partially for business purposes and partially for personal use by its shareholders. ... In anticipation of the termination of the logging agreements referred to in paragraph 2 hereof, and under an agreement made as of the 15th day of December, 1959, the Appellant agreed with Rayonier Canada Limited to cause a new company to be incorporated as a wholly-owned subsidiary and to sell to the said new company all land, timber, camp buildings, equipment, machinery and other goods and property forming part of, or used in connection with the carrying out of the said logging agreements with Rayonier Canada Limited, the latter agreeing that it or its nominee would purchase al! ... Appellant states in its Notice of Appeal that it owned the vessel “Norsal" which was used by it in connection with its logging business but there was no need for this when this business ceased and it then endeavoured, unsuccessfully, to dispose of it by sale. ...
FCTD
Columbia Records of Canada Ltd. v. Minister of National Revenue, [1971] CTC 839, 71 DTC 5486
He gave financial backing to his sons and son-in-law in connection with the purchase and development of the shopping centre. ... Snow said that in 1961 they had plans to construct a chain of shopping centres, including a Gold Shield Plaza at Cumming Avenue, in connection with which they approached Dominion Stores. ... I shall refer to some items. 2345 Yonge Street looked to the Toronto-Dominion Bank for its initial funds in connection with the shopping centre. ...
FCTD
IBM Canada Ltd. v. Canada, 2001 FCT 1175
He also stated that 75% of the appellant's asphalt production was used in connection with its paving business and that 25% thereof was sold to third parties. ... Justice Major summarises as follows one of the arguments put forward by the appellant: In this appeal, Will-Kare admits that asphalt supplied in connection with its paving services is provided pursuant to a contract for work and materials. ... [Underlining added] [24] The Defendant relies on the Supreme Court's decision in Will-Kare, supra, for the proposition that goods supplied in connection with the provision of a service, namely a contract for work and materials, are not goods for sale in the context of tax legislation. ...
FCTD
Patry v. Canada (Attorney General), 2011 FC 1032
[26] The Patrys also point to connections between themselves and the person who commissioned one of the affidavits filed in this proceeding by the respondent. These connections include the fact that they bought a house from the spouse of the person commissioning the affidavit. The Patrys submit that these connections give rise to a reasonable apprehension of bias on the part of the BFTSO ...
FCTD
Iao v. Canada (Citizenship and Immigration), 2013 FC 1253
[15] There is a close connection between the Regulations and the IAD’s functions. ... Iao’s quality of connection to China is greater than it is to Canada, based on the following: i. ... Iao’s immediate family and dependents, her pattern of physical presence in Canada, and the quality of her connection to Canada relative to her connection with China, the IAD appears to have assessed the period right up to its decision, dated February 1, 2013. ...