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FCTD

Omaboe v. Canada (Citizenship and Immigration), 2019 FC 1135

In connection with the intervention, the Minister filed information indicating that the U.S. ... He testified that when he originally filled out documents in connection with his refugee claim he made mistakes about his travel route to Canada and the name on the passport he had used because he was scared and his mind was “all over the place.”   ...
FCTD

Diallo v. Canada (Citizenship and Immigration), 2019 FC 1324

Diallo in order to kill him in connection with political activities in 2013. (3) Mr.  ... For all these reasons, I am not satisfied that the applicant is at risk in connection with his political involvement. [22]   The Respondent submits that the Officer considered all of Mr.  ...
FCTD

Canadian Pacific Railway Company v. Canada, 2019 FC 1531

The CRA subsequently also denied these objections, taking the position that no ETA provision permits fuel tax refunds. [12]   CPR thus seeks repayment of these fuel tax refunds in this action, as well as a declaration that the CRA is not entitled to collect fuel taxes on fuel purchased, consumed, or used in connection with CPR’s main line. ... In addition, CPR seeks a declaration that the Crown cannot collect tax imposed under the ITA on income earned by CPR in connection with the operation of its railway as originally defined in the CPR Act. [13]   CPR alleges that the imposition of both taxes are wrongful breaches of (i) the Contract, (ii) the CPR Act, (iii) the CPR Charter, and (iv) the Constitution of Canada, for which CPR has filed a Notice of Constitutional Question in accordance with the Federal Courts Act, RSC, 1985, c F-7 [FC Act] and FC Rules. ...
FCTD

Canada (National Revenue) v. CN Construction Networks Ltd., 2020 FC 775

Ciciarelli did not file notices of objection to the assessments. [5]   In connection with the CRA’s collection actions regarding Mr. ... Ciciarelli’s significant prior non-compliance with the ITA and Orders of this Court made in connection with the CRA’s audits of his other business interests warrant an order requiring delivery of the Material to the CRA. ...
FCTD

Her Majesty the Queen v. Ichi Canada Limited, [1994] 2 CTC 350, 94 DTC 6608

November 24, 1989 to July 24, 1990: Correspondence and telephone attendances between counsel for the parties in connection with possible amendment to the defence with counsel for the defendant advising, July 24, 1990, that she was still awaiting information from her client; 8. ... November 19, 1990 and April 25, 1991: Correspondence between counsel for the parties in connection with plaintiff's list of documents; 10. ...
FCTD

Ilori v. Canada (Citizenship and Immigration), 2021 FC 627

It is not known whether the Judge faced that issue when preparing the decision that issued two months after the hearing. [12] More significantly, however, the Citizenship Judge’s decision refers to several documents that the Judge reviewed in connection with his assessment of whether Mr. ... For example, the typed, transcribed hearing notes state the following: “still has house; owned houses in 2010; still live in on [sic] of these houses; manage houses; still own hotel; owned in 2010; was getting income in 2010; partner manage accounting firm; started early 2000 while still working at CFAO; used identity to start firm; started CFAO as internal auditor…” The Judge mentioned these factors in connection with the credibility concerns outlined in his decision. [24] According to this Court’s case law, there are three separate tests from which a citizenship judge can choose, one of which is quantitative based strictly on the physical presence requirements, while the other two are more qualitative in nature: Miji v Canada (Citizenship and Immigration), 2015 FC 142 [Miji] at para 19. ...
FCTD

Robert D. Blake v. Her Majesty the Queen, [1991] 2 CTC 236

See also paragraph 139(1)(ae) of the Income Tax Act which includes as "personal and living expenses" and therefore not deductible for tax purposes, the expenses of properties maintained by the taxpayer for his own use and benefit, and not maintained in connection with a business carried on for profit or with a reasonable expectation of profit. ... The expenses deducted by the plaintiff from farm revenue which caused the losses were not incurred for the purpose of gaining or producing income from a business or property but were the expenses of property maintained by the plaintiff for the use of his family and not maintained in connection with a business carried on for profit or with a reasonable expectation of profit. ...
FCTD

J. Stuart Robertson v. Her Majesty the Queen, [1988] 1 CTC 111, 88 DTC 6071

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. ...
FCTD

Nova, an Alberta Corporation v. Her Majesty the Queen, [1987] 1 CTC 265, 87 DTC 5146

:—The only issue left to be resolved in this income tax appeal is whether all pipes and valves located between the outlet connection of the main pipeline and the compressor stations (and the meter stations) are to be treated as an integral part of the “pipeline” or of the compressor stations (or the meter facilities) for the purposes of capital cost allowance. ... The Province of Alberta Pipeline Act, 1975 defines a pipeline as follows: “pipeline” means a gas line, oil line, fluids line, multi-phase line, solids line, secondary line, distribution line or flow line. and gas line is defined as follows: “gas line” means a pipe for the transmission of gas from a secondary line or storage facility to a distribution centre or storage facility and includes installations in connection therewith but does not include a multiphase line, secondary line, flow line or distribution line. ...
FCTD

Ministre Du Revenu National v. Intermodal Container Transport Ltée, [1999] 4 CTC 303, 99 DTC 5619

I Ford 9000 truck, orange NS/ W90JVHA6973 with boom, registration L86164; 3. 1 Grove crane, model 4080 NS/ R21365, registration FN98335; There are two paradoxes in connection with these cranes. ... However, it covers two distinct properties, namely: 6. 1 Pontiac Transport vehicle, green, registration FMI 2051, NS/I GMDU06D2RT213152; 7. 1 Jaguar vehicle, grey, without engine, registration FE96635; There is also a paradox in connection with this latter contract. ...

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