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FCTD

Dr. Lemuel F. Prowsh v. Minister of National Revenue, [1971] CTC 736, 71 DTC 5443

The automobile which the Appellant owns and for which he is claiming expenses for tax purposes is the automobile used by him at all times in connection with his practice. ... He stated also that he spent about 12 hours per week there in administrative work in connection with his practice, discussing with his wife the fees to be charged, reduced or remitted due to particular circumstances of the patients; but that he performed no medical services there except for a very few times each year when a patient might come to the house in advance of an operation to discuss the type of anaesthesia that might be used. I think it highly probable however, that practically all the time spent in the office at home by either himself or his wife in connection with his practice was in their capacities as president and secretary of Anesthesia Facilities Ltd. and perhaps in its office there. ...
FCTD

Sunshine Uniform Supply (1983) Ltd. v. Canada, docket T-3466-90

Its business was the conduct of research, particularly in connection with construction. ... Shead"s connections with Anaquan and Mr. McLellan, Anaquan"s first president, go back to 1984 when he incorporated the company and subsequently acted as an adviser to it. ... Shead"s long standing connection with Anaquan and Mr. McLellan. Indeed, Mr. ...
FCTD

Robinson v. Canada (National Revenue), 2018 FC 825

Robinson had mentioned his age as being a factor there was no connection found between his age and his ability to pay his taxes. ... The Decision Maker indicated he had reviewed the cases and found no connection between the facts of those cases and Mr.  ... He claims that the non-filer NOA was the cause of the penalty and interest charged to him and it was an error on the part of CRA to issue it. (1)   The Alleged Causal Connections [91]   When asked at the hearing to explain to the Court the causal connection between the issuance of the non-filer NOA and the claim that Mr.  ...
FCTD

Bell Media Inc. v. GoldTV.biz, 2019 FC 1432

The Third Party Respondents Distributel Communications Limited [Distributel] and Cogeco Connexion Inc. ... In doing so the user will only rely on the ISP to facilitate the connection to the VPN; all other Internet connections are initiated through the VPN thereby avoiding any blocking undertaken by the ISP. ... DBA EASTLINK COGECO CONNEXION INC. DISTRIBUTEL COMMUNICATIONS LIMITED FIDO SOLUTIONS INC. ...
FCTD

Blue Bridge Trust Company Inc. v. Canada (National Revenue), 2020 FC 893

It should be noted that the Minister does not represent France and has no connection to this matter other than as the Canadian competent authority for obtaining the information and documents required by France under the Convention. [74]   France clearly has a genuine and valid interest in opposing Blue Bridge’s applications because the declaratory order sought would contravene a decision of a French court having jurisdiction in the matter. [75]   It is not for Blue Bridge to judge the appropriateness of France’s legislative choices in the arena of taxation or to deprive its tax authorities of the information it could use to perform its auditing functions. ... The requests made by France show the connections between the French residents and the Trusts at issue in this judgment. The Minister has no obligation whatsoever to verify the information supplied by France. [114]   Having studied the requests from the French authorities in connection with the French residents under investigation, the Minister assessed the foreseeable relevance of the required information, pursuant to Article 26(1) of the Convention. ...
FCTD

Rahman v. Canada (Attorney General), 2022 FC 806

In this connection I also note the Federal Court of Appeal’s recent decision holding judicial review of procedural fairness issues is conducted on the correctness standard: see Canadian Association of Refugee Lawyers v. ... I find nothing unreasonable in the identification and weighing of the evidence by the Minister’s Delegate in this connection; it comports with constraining jurisprudence and was open on the record. [56] Second, the Applicant submits the Minister’s Delegate erred in their assessment of her medical condition. ... There should be and are guidelines to be factored into decisions in this connection. ...
FCTD

The Queen v. Demers, 81 DTC 5256, [1981] CTC 282 (FCTD)

With respect to costs, it is clear that the provisions of subsection 178(2) of the Act providing for payment by the Minister of “all reasonable and proper costs of the taxpayer” in connection with the appeal are applicable, and it is hereby ordered accordingly. ...
FCTD

The Queen v. Augart, 92 DTC 6610, [1992] 2 CTC 412 (FCTD)

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". ...
FCTD

Aliments CA-MO Foods Inc. v. The Queen, 80 DTC 6043, [1980] CTC 75 (FCTD)

There was no connection linking the PAM customers to that company, and no pressure was exercised by PAM based on the sale of the list to ensure that its customers would henceforth buy from CA-MO. ...
FCTD

Zygocki v. The Queen, 84 DTC 6283, [1984] CTC 280 (FCTD)

The plaintiff, who had a 50 per cent interest in the property, reported in her 1977 tax return a net loss of $57,110 as a capital loss arising out of the sale of the property in November of that year, the property having been sold for less than the original purchase price and presumably some expenses having been incurred in connection therewith. ...

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