Search - connection

Soucy was included in a pool of qualified candidates in connection with an advertised external appointment process, but he was not appointed to the position sought. ... Soucy submitted an application in connection with an advertised external appointment process seeking to fill the position of Fire Chief at group and level FR-6 [the Position] and establish a pool of candidates to fill similar positions within the department at 2nd Canadian Division Support Base Valcartier, in Quebec. ... Soucy held the position of Chief Fire Inspector for the Department of National Defence [the Department] in Wainwright, Alberta. [8]   The Statement of Merit Criteria and Conditions of Employment advertised in connection with the Position set out the essential qualifications, including the personal suitability criterion of “Working Effectively with Others”, the asset qualifications, and the conditions of employment for the Position (certified record at p 138). [9]   In May 2016, Mr.  ...

Obligation de fournir des renseignements ou documents étrangers (2) Malgré les autres dispositions de la présente loi, le ministre peut, par avis signifié à personne ou envoyé par courrier recommandé ou certifié, exiger d’une personne résidant au Canada ou d’une personne n’y résidant pas mais y exploitant une entreprise de fournir des renseignements ou documents étrangers. [32]   Bayer Canada says that the Requirement is unreasonable because the connection between the information sought and the subject-matter of the audit is too remote. ... However, a rational connection must exist between the information sought and the administration and enforcement of the ITA (Saipem at para 26). [40]   In this case, the Requirement is for disclosure of: […] all contracts (with amendments), license agreements, royalty agreements and/or other legal agreements between Bayer AG, or any other member of the Bayer Group, and a third party related to the purchases and/or sale of pharmaceutical products, where advertising, promotion, detailing, marketing and/or distribution functions were undertaken. [41]   The information sought includes all distribution agreements with 21 named companies that operate at arm’s length from the Bayer Group of companies. ... The sole constraint placed on the Minister is that a rational connection must exist between the information sought and the administration and enforcement of the ITA (Saipem at para 26). ...

., [1971] F.C. 421; [1971] C.T.C. 818; 71 D.T.C. 5469 (F.C.T.D.) held that the cost of engineering studies in connection with a proposed hydroelectric development were properly deductible as an ordinary business expense on the ground that the expenditure was laid out as part of the operation and cost of the business. ... The learned judge immediately went on to conclude: The conclusion to be drawn is unavoidable: the legal expenses here in question — those incurred in an effort to complete the take-over as well as those incurred in seeking to get compensation in lieu of shares — were outlays associated with an “investment transaction", they were made in connection with the acquisition of a capital asset. ... It is well established that it is never necessary to show a causal connection between an expenditure and a receipt. ...

However, they do not demonstrate any connection between the two. [33] The UBC offer of a position was contingent on the Applicant funding her own way; the Letter of Offer does not make any reference to the funding from the Exchange Program. ... Canada offers awards to full-time, permanent teaching or research staff, master’s or doctoral graduates so that upon their return home they can make a distinctive contribution to life in China and to mutual understanding between Canada and China. [34] The Applicant argues that the Officer’s conclusion that she had not received “wages” was not explicitly based on the lack of connection or the purpose of the Exchange Program, and so this cannot be invoked now to sustain the decision. ... The further documents do not establish a connection between the Visiting Lecturer appointment and the scholarship. [49] I find that none of the letters the Applicant submitted in support of her application state that the scholarship was to compensate her for her “services” to UBC. ...

By an agreement dated November 29, 1979 (the ‘Transfer Agreement’) Silver Creek- Cedarwood acquired the Projects in consideration for it assuming the liability of $1,700,500 owing by the vendor to the Defendant. 5 By agreement dated November 29, 1979 (the ‘Development Agreement’) among Silver Creek-Cedarwood, the Defendant and the Promoters, i) the Defendant agreed to complete the projects for $9,522,976 and provide certain initial services essential to Silver Creek-Cedarwood as described in paragraph 6 below, and ii) the Promoters and the Defendant agreed to provide certain covenants and guarantees in connection with the Projects. 6. ... By agreement dated June 30, 1980 (the ‘Stonehill Development Agreement’) among the Stonehill Partnership, the Defendant and the Promoters, i) the Defendant agreed to complete the Stonehill Project and provide certain initial services essential to the Stonehill Partnership for a fixed price, and ii) the Promoters and the Defendant agreed to provide certain covenants and guarantees in connection with the Stonehill Project. 11. ... By agreement dated October 21, 1981 (the ‘Purchase and Development Agreement’) among the Burnhill Partnership, the Defendant and the Promoters, i) the Defendant agreed to construct the Burnhill Project and provide certain initial services essential to the Bumhill Partnership for a fixed price, and ii) the Promoters and the Defendant agreed to provide certain covenants and guarantees in connection with the Burnhill Project. 16. ...

He testified that he was consulted in connection with the deceased’s negotiations with the Smith Company and was familiar with the arrangements made by the Wisener Companies to obtain the necessary capital. ... Counsel for the appellant submitted that the policy was taken out to provide a method to satisfy the deceased’s obligation to the bank in the event of his death, that the taking out of the policy was in relation to his position as a lender of funds to the company, and had nothing to do with his status as an officer or employee of the company; that the policy was not effected “in respect of, in the course of or by virtue of” his office or employment; and that those words as used in the Act imply a direct causal connection between the taking out of a policy and the office or employment of the insured person as an employee of the company. ... In the present case I do not think it can be said that the insurance was taken out “in respect of” or “by virtue of” the deceased’s office or employment, for it was taken out predominantly as an incident or step in the method adopted to raise needed funds for the company and because the deceased incurred liability to the bank as a borrower of a portion of the funds lent to the company in that connection. ...

President Thorson (as he then was) said in the case of Losey v MNR, [1957] CTC 146 at 152; 57 DTC 1098 at 1101: But the value of the goodwill of a business is what a purchaser would be willing to give for the chance of being able to keep the connection of which it consists.... ... In the case at bar, it is clear that the plaintiff purchased the Mac- Innes connection” and the goodwill attaching thereto together with a partial restrictive covenant (Hayes’ covenant not to carry on a general insurance business as Macinnes & Co). ... It is the benefit and advantage of the good name, reputation, and connection to a business. ...

Guy Charron testified and stated that he was in no better position to make the payments personally than was the bankrupt company and on the threat of making a personal assignment in bankruptcy, a settlement was made on April 11, 1973 between him, the four brothers, Gilles, Pierre-Paul, Réjean and Guy, and the mother Julia Thibault, whereby they were paid the sum of $17,000 in full settlement of all claims existing or future in connection with the agreements of March 11, 1968. The proceedings in the Quebec courts were withdrawn and Charron agreed to pay the fees of counsel in connection with the notices of opposition to the tax assessments and that if any amounts were received by the Thibaults from the Minister of National Revenue as a result of these oppositions or any future oppositions, these sums would remain the entire property of the Thibaults. ... No break-down was made or attempted as to what portion of the settlement was attributable to tax liability and what portion to annuity payments, this evidence only having been presented with a view to establishing that all possible efforts had been made to collect not only the annuity payments but the additional tax on the tax assessed on the income portion thereof, and that these efforts had yielded minimal results, no dividend having been paid or anticipated in connection with the claim against Guy Charron Limitée. 4 The only issues before the Court in the present appeal are first, whether tax can be assessed on amounts which a taxpayer is entitled to claim by virtue of a contract but which he is unable to collect, and second, whether the agreement to indemnify the taxpayer against any income tax assessed as a result of the annuity payment would only come into play when such an assessment was made—in the present case in 1971—or whether, since the tax was allegedly due for the 1968 and 1969 years, the right to claim indemnity should be considered as applicable to those years even though no reassessment was made by the Minister of National Revenue until 1971. 5 There is some jurisprudence which, although not directly in point, throws some light on the matter. ...

The respondent objects to the transmission of the documents requested in items 5c) to g) of the Notice of Application on various grounds: the relevance of the documents, solicitor-client privilege, litigation privilege, and the very existence of certain documents. [11] The respondent explains the reasons for its opposition to the transmission of these documents: Point Description of requested document(s) Reason given by the respondent in the letter of opposition 5c) All communications between Caroll Stevens, Janie Groleau and any other CRA employee or representative in connection with the processing of the applicant’s Second Request for Relief. ... The respondent has no proof of their existence. 5d) All communications between other CRA employees or representatives in connection with the processing of the applicant’s Second Request for Relief. 5e) All documents sent by CRA employees or representatives to Ian Demers or another Justice Canada representative referring to documents that the applicant or one of his representatives had provided to the CRA since 2000 The respondent objects to the transmission of any document that has not been analyzed by the Minister’s delegate for reasons of relevance, solicitor-client privilege and litigation privilege. 5f) The identities and positions of the CRA employees or representatives who provided the documents referred to in item 5e). The respondent objects to the transmission of any document that has not been analyzed by the Minister’s delegate for reasons of relevance. 5g) The identities and positions of the CRA employees or representatives who instructed Ian Demers or another representative of Justice Canada in connection with the judicial review proceedings initiated by the applicant following the refusal of his first request for relief. ...

The Applicant received her TFSA proceeds in the amount of $59,779.24 and opted to transfer the amount to his TFSA account on June 18, 2019 [the Over-Contribution]. [6] The Applicant was assessed by the CRA on July 14, 2020, in respect of the Over-Contribution in connection with the 2019 taxation year. ... Exception to Rule 302 of the Federal Courts Rules [16] The Applicant has put in issue the reasonableness of both the Second Decision and the first level decision of the CRA in connection with his 2020 tax year. ... The Respondent alternatively submits that if the Court is inclined to look past these irregularities, it objects to the inclusion of documents in the Application Record that were not before the CRA when it rendered the Second Decision or do not fall under any of the exceptions to the rule recognized in Association of Universities and Colleges of Canada v Canadian Copyright Licensing Agency (Access Copyright), 2012 FCA 22 at paragraphs 19-20 [Access Copyright]. [19] The Respondent has raised a valid issue in connection with the commissioning of the Affidavit. ...