Search - connection

The plaintiff performed his duties in connection with a contract (the “contract”) made between the province, as executing agency, and the Canadian International Development Agency (“CIDA”), an agency of the government of Canada’s Department of External Affairs. ... That paragraph provides: 7(1) Irrespective of any assessment of land under this Act, every person occupying or using land for the purpose of, or in connection with, any business mentioned or described in this section, shall be assessed for a sum to be called “business assessment” to be computed by reference to the assessed value of the land so occupied or used by him as follows:... ... There is little doubt that the Department recovered a fair share of its costs of the services provided in connection with the contract. ...

The credit provided to Cedar Canada was a revolving line of credit of up to $40 million, the proceeds of which would be used to repay certain indebtedness of Cedar Canada to BT Commercial Corporation, to finance the working capital requirements of Cedar Canada, and DBI, Steen and Davie in the ordinary course of business and to pay fees and expenses incurred in connection with the transaction ... Marengere, Matossian and Amyot, (the "Settlement Obligations"), to repay certain outstanding tax obligations owed to Revenue Canada and to finance working capital requirements of the Borrower and DBI, Steen and Davie in the ordinary course of business and to pay fees and expenses incurred in connection herewith ... In this connection, Ms. Dazé said that $2,700,000, according to the Settlement Agreement, is payable to Services MLM but pursuant to that agreement, this amount is to be paid to Wellgate, an offshore corporation having no address and having no assets in Canada. ...

  [45]     As will be seen, Justice Gonthier, on behalf of the Court, moved away, in the context of determining the situs of the receipt of such benefits, from the exclusive factor of the location of the debtor to a search for and the balancing of relevant connection factors.  ... However the parties have agreed that the uses made by the Company of the leased reserve land were "related to the production of pulp",3 the activity in connection with which the appellants were employed. ... [Emphasis mine]   [74]     He then stated “so too, where investment income is at issue, it must be viewed in relation to its connection to the Reserve, its benefit to the traditional native way of life, its potential danger to the erosion of native property and the extent to which it may be considered as being derived from economic mainstream activity.”  ...

The business of the Appellant is that of manufacture and research, the research being of such a character as to bring the expenses in connection therewith within the provisions of section 72 of the Income Tax Act. 9. ... There is no necessary connection between Section 56 and Section 132, since the Minister may exact penalties under Section 56 (extrajudicially so to speak, although subject to taxpayer challenge) without summary conviction proceedings being taken under Section’132. A connection arises however between Section 56 and Section 132(3) when there has been a conviction under Section 132(1) (d). ...

Pursuant to a contract in writing made the 18th day of November, 1974, Samoth acquired from Century 21 US in consideration for the sum of $100,000 the exclusive right to sell Century 21 franchises to licensed real estate brokers in the Dominion of Canada and to use the Century 21 name, service marks and systems in connection therewith. 5. ... Such consent shall not be unreasonably withheld; however, Subfranchisor shall reimburse Century 21 for all costs and expenses incurred in connection with any such assignment or proposed assignment, including reasonable costs not to exceed $1,000.00 of investigating the proposed assignee, and attorney's fees not to exceed $1,000.00. ... Said insurance shall insure Franchisee against any liability which may arise in connection with the operation of his real estate brokerage business. ...

., that connection being established, amongst various factors, by Norsk’s place of management". ... This connotes the existence of some sort of causal connection or, in the least, some relationship of proximity. ... In this connection, I find persuasive the submission that only those corporations that are liable to taxation for the full amount of their worldwide income meet the definition of "resident" in the Canada-U.S. ...

This provision, which is still in effect, requires any class of prescribed persons to make information returns required in connection with assessments under the ITA. ... A group with no connection to the ITA could be hard to ascertain within the framework of a power granted for the administration and enforcement of the ITA. [70]   In this case, the Minister wants to know the identity of Hydro-Québec’s business customers. ... When the group is generic and has no connection to the ITA, and information can be requested outside the scope of the ITA (such as identifying the business clients of a public utility), there is no longer any limit on the fishing expedition. ...

The Plaintiff from time to time produced films in Canada during those years but its production crews in Canada had no effective connection with Fox Canada or the Plaintiffs Canadian branch. 28. ... Every non-resident person shall pay an income tax of 25% on every amount that a person resident in Canada pays or credits, or is deemed by Part I to pay or credit, to him as, on account or in lieu of payment of, or in satisfaction of, payment for a right in or to the use of (a) a motion picture film, or (b) a film or video tape for use in connection with television that has been or is to be used or reproduced in Canada. ...

In addition, all of the truck cabs and chassis and mixers listed in paragraphs 6 and 11 above were acquired by the plaintiff principally for the manufacturing, processing and delivery of concrete in connection with its major business activity of manufacturing and processing concrete for sale. 18. ... The defendant's position In reassessing the plaintiff's 1983, 1984, 1985, and 1986 taxation years the Minister proceeded on the basis that: (i) the plaintiff's mixers were trucks designed for use on highways and streets (therefore not qualified” property); and (ii) the mixers were acquired principally for the purpose of manufacturing, processing and delivery of concrete in connection with its major business activity of manufacturing and processing concrete for sale and were not, therefore, acquired for the purpose of construction in Canada, in the course of carrying on business (therefore not qualified construction equipment). ...

It is well established law that there need not be a connection by way of a physical relationship or integration between the farming and the other source of income, in order for the two sources to be “in combination” for the purposes of subsection 31(1).!! ... Due to the inherent connection between the activities of Wolfgang and the activities of the Plaintiff, during the relevant taxation years, I am satisfied that the Plaintiff’s major preoccupation was the farm operation. ...