Search - connection

Results 181 - 190 of 1090 for connection
FCTD

Gillis v. The Queen, 78 DTC 6103, [1978] CTC 44 (FCTD)

He had known of the Tax Review Board’s decision since June 30, 1976 and in that connection he had not been frank with the Court. ... He had no income that year from the farm and the total amount of his expenditures which he claimed to have had in connection with his farm came to $4,154.47. ... (ae) “personal or living expenses” include (i) 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 or with a reasonable expectation of profit. ...
FCTD

McNeill v. The Queen, 86 DTC 6477, [1986] 2 CTC 352, [1986] 2 CTC 364, [1986] DTC 6486 (FCTD)

Finally he pointed out that the amount received by the plaintiff did not qualify as one of the exceptions which are provided in paragraph 6(1)(b) of the Act: Personal or Living Expenses 6(1)(b) all amounts received by him in the year as an allowance for personal or living expenses or as an allowance for any other purpose, except (i) travelling or personal or living expense allowances (A) expressly fixed in an Act of the Parliament of Canada, or (B) paid under the authority of the Treasury Board to a person who was appointed or whose services were engaged pursuant to the Inquiries Act, in respect of the discharge of his duties relating to such appointment or engagement, (ii) travelling and separation allowances received under service regulations as a member of the Canadian Forces, (iii) representation or other special allowances received in respect of a period of absence from Canada as a person described in paragraph 250(1)(b), (c) or (d), (iv) representation or other special allowances received by an agent-general of a province in respect of a period while he was in Ottawa as the agentgeneral of the province, (v) reasonable allowances for travelling expenses received by an employee from his employer in respect of a period when he was employed in connection with the selling of property or negotiating of contracts for his employer, (vi) reasonable allowances received by a minister or clergyman in charge of or ministering to a diocese, parish or congregation for expenses for transportation incident to the discharge of the duties of his office or employment, (vii) allowances (not in excess of reasonable amounts) for travelling expenses received by an employee (other than an employee employed in connection with the selling of property or negotiating of contracts for his employer) from his employer if they were computed by reference to time actually spent by the employee travelling away from (A) the municipality where the employer's establishment at which the employee ordinarily worked or to which he ordinarily made his reports was located, and (B) the metropolitan area, if there is one, where that establishment was located, in the performance of the duties of his office or employment, (viii) such part of the aggregate of allowances received by a volunteer fireman from a government, municipality or other public authority for expenses incurred by him in respect of, in the course of, or by virtue of the discharge of his duties as a volunteer fireman, as does not exceed $300, or (ix) allowances (not in excess of reasonable amounts) received by an employee from his employer in respect of any child of the employee living away from the employee's domestic establishment in the place where the employee is required by reason of his employment to live and in full-time attendance at a school in which the language primarily used for instruction is the official language of Canada primarily used by the employee if (A) a school suitable for that child primarily using that language of instruction is not available in the place where the employee is so required to live, and (B) the school that the child attends is the school closest to that place in which that language is the language primarily used for instruction; Counsel for the plaintiff, on the other hand, submitted that the payment did not constitute income from office or employment. ... The Ransom case, supra, also emphasized a similar connection between the rendering of service and the payment of the amount before the compensation was to be considered income from an office or employment. ... Savage were not in relation to or in connection with her employment. As Mr. ...
FCTD

Lafarge Canada Inc. c. La Reine, 2001 FCT 194

In paragraph 26 of his reasons, Major J. summarizes one of the arguments of the appellant Will-Kare as follows: 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. Nevertheless, Will-Kare requests that we adopt the Halliburton and Nowsco ordinary meaning interpretation such that the manufacturing of goods for sale includes all manufactured goods supplied to a customer for consideration, regardless of whether paving services are provided in connection with that supply. ... For the taxation years in issue, approximately 75 percent of the asphalt produced by the Will-Kare's plant was supplied in connection with Will-Kare's paving services. ...
FCTD

Her Majesty the Queen v. Saint John Shipbuilding & Dry Dock Co LTD, [1979] CTC 380, 79 DTC 5297

These payments resulted from the acquisition by defendant from Com/Code by agreement entered into on or about April 8, 1971, of the right to use in Canada that company’s Autokon-I System of computerized information in connection with defendant’s shipbuilding operation. ... I have expressly avoided the use of the word “bought” or “leased” in connection with the acquisition of the right to use the system by defendant and others who obtained it from Com/Code since it is the key to the whole problem. ... This is evident from the various dictionary definitions of the word “royalty” when used in connection with a sum payable. ...
FCTD

Shabro Investments Limited v. Her Majesty the Queen, [1977] CTC 429, 77 DTC 5293

The comments of the present Associate Chief Justice of this Court made in the Vancouver Tugboat case regarding reference to cases decided in other countries would seem particularly appropriate in connection with the Regenstein case. ... The sole question involved was whether one element of the expenses incurred in connection with the leasing of water heaters was an expense of earning income which was deductible in computing its annual profit from the business notwithstanding paragraph 12(1)(b) of the Income Tax Act then in force. ... In connection with those expenditures which are within the scope of paragraph (a) Jackett, P (as he was then) said, inter alia [p 256 [5206]]: Where the inside layer of the ship’s bottom, which also serves as the floor for the ship’s cargo-carrying holds, has to be replaced, in whole or in part, by reason of wear and tear and of damage caused by the cargo carried in the ship, it seems clear to me that the expense falls in the same class as the expenses of replacement of portions of the outside skin. ...
FCTD

Begum v. Canada (Citizenship and Immigration), 2017 FC 409

Thus, there is no sufficient causal connection between the MNI requirement and the deprivation of liberty or security of the person. ... The evidence was often nebulous· and did not demonstrate a causal connection that produced a disproportionate impact or an adverse effect. ... [footnotes omitted] (d)   Conclusion on s 15 [179]   In the end, as the Decision makes clear, the Applicant simply failed to establish a causal connection between the denial of her sponsorship for MNI reasons and the intersectional grounds she raised. ...
FCTD

Freeway Properties Inc. v The Queen, 85 DTC 5183, [1985] 1 CTC 222 (FCTD)

This is not a situation where the realty was acquired with funds awaiting use in connection with some other business of the company. ... So far as the wording of the “objects” of the corporation is concerned the plaintiff had no function to perform, no business to pursue and nothing to do except in connection with the realty. ... The same principle of interdependence between what might otherwise be considered passive income and active business operations was recognized by the Court of Appeal in the case of The Queen v Marsh & McLennan Ltd, [1983] CTC 231; 83 DTC 5180 where we find the following statement at 242 [5189]: To use the words employed by Rowlatt J in Scales v George Thompson and Company Limited, [1927] 13 TC 83, on the facts of this case there was between the broker’s business and the investments an inter-connection, an interlacing, an interdependence, a unity embracing the investments and the business. ...
FCTD

Corlite Petroleums Ltd. v. The Queen, 76 DTC 6450, [1976] CTC 766 (FCTD)

Thereafter an agreement was executed on or about July 24, 1965, under which the plaintiff agreed to sell the claims to Churchill for shares in a new company to be incorporated and to execute and deliver a bill of sale of the claims in escrow to a firm of solicitors for delivery to Churchill upon receipt of a statutory declaration by a representative of Churchill stating that by November 30, 1966 Churchill gave notice to Corlite of its intention to equip the property for production and had paid Corlite’s costs and expenses in connection with the claims. Later, by an agreement dated November 29, 1965, the agreement of July 29 was terminated and a new deal was made under which the plaintiff sold the claims to Churchill for 225,000 paid-up shares of its capital stock plus $45,000 in respect of the plaintiff’s costs and expenses in connection with the property and the assumption by Churchill of the plaintiff’s obligations under the agreement with the prospectors. ... If either was to be undertaken, the operation would have a better chance of success if carried out in connection with the development of other properties in the area. ...
FCTD

The Queen v. Boychuk, 78 DTC 6316, [1978] CTC 451 (FCTD)

If the decision on this issue is adverse to the defendant, there will be an issue to decide whether the defendant incurred deductible expenses in connection with the venture, and if so, the amount of such expenses. ... From about the end of April Tesluk paid most of the expenses incurred by the Lavoies and Gagnon in connection with prospecting. ... This includes expenses incurred in connection with an inspection ordered for 5 claims restaked by Gerard Gagnon and carried out on August 31 and September 1, 1971. ...
FCTD

Blanchard v. The Queen, 92 DTC 6585, [1992] 2 CTC 403 (FCTD)

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. ... The ETAP program and the payment did not have any connection with the plaintiff's employment other than that it was paid by an agent of the employer; it did not upgrade him or make him a more valuable employee, nor did it create an opportunity for promotion. ...

Pages