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Results 51 - 60 of 1090 for connection
FCTD
Andrew Potulicki v. Her Majesty the Queen, [1993] 1 CTC 417, 93 DTC 5196
.:— Background This is an appeal by the taxpayer from a tax assessment for the years 1984 and 1985 where the respondent disallowed certain business expenses claimed by the appellant in connection with a business named Rainbow Colour Printing Plate Services. ... S.C. 1970-71-72, c. 63) (the "Act"), treats these expenses as having been incurred for the use of or benefit to a taxpayer, it should exclude those expenses incurred in connection with a business carried out for profit or with a reasonable expectation of profit. ... Although the definition of “business” in subsection 248(1) of the Act does not specifically qualify a business as being one in which a project is realized or in which there is a reasonable expectation that a profit will come out of it, the principle is found in the definition of "personal and living expenses" in subsection 248(1) where there is found the expression ”...in connection with a business carried on for profit or with a reasonable expectation of profit". ...
FCTD
Minister of National Revenue v. Ablan Leon (1964) Limited, [1974] CTC 610, 74 DTC 6451
In this connection, there are many pitfalls to watch for, some of which are set out below. a) The dangers of certain sections of the Income Tax Act. ... After that the situation in connection with that $50,000 becomes confused. ... On behalf of the respondent, the issuing of the cheques by Mr Egnatios and his evidence in connection with an intention to form a partnership to acquire and operate the Leon furniture business were stressed in connection with the submission that the trusts were created even if the instruments of settlement were invalid. ...
FCTD
The Queen v. Lambert, 74 DTC 6368, [1974] CTC 516 (FCTD), aff'd supra.
This disposes of the most serious argument raised by defendant, but there were other arguments raised in connection with the various motions which can be dealt with briefly. ... The procedure adopted in the present case was that always followed and I find no irregularity in connection with the seizures made or the order for examination. ... During the course of such examination he may testify with the protection of the Canada Evidence Act in connection with the use of any of his answers in criminal proceedings against him other than a prosecution for perjury in connection with the evidence he gives. ...
FCTD
The Queen v. Saskatoon Drug & Stationery Co. Ltd., 78 DTC 6396, [1978] CTC 578 (FCTD)
(leasehold interests and right to enter into leases as set forth on page 7 hereof), (emphasis added) and assets belonging to or used in connection wit hthe said businesses of the vendor, aS a going concern,... ... [3] provided that premiums or like consideration “demanded and given in connection with leasehold estates” should, as the case may be, either be included in or deductible from taxable income, to adopt Canadian terminology. The High Court of Australia has held that consideration for local goodwill was paid and received “in connection with leasehold estates” in sales of going concerns where the vendor granted a lease of the subject premises.! ...
FCTD
Commonwealth Construction Co. Ltd. v. The Queen, 82 DTC 6152, [1982] CTC 167 (FCTD), aff'd 84 DTC 6420, [1984] CTC 338 (FCA)
After he had discussed the adequacy of the decision made with both management and the companys counsel in connection with the appeal situation he would only have commented on management’s appraisal of it as shown in the financial statements if he had thought they were flagrantly wrong. ... The case of MNR v Atlantic Engine Rebuilders, [1964] CTC 268; 64 DTC 5178; [1967] CTC 230; 67 DTC 5155, was also referred to by plaintiff but here again it dealt with taxation of a deposit which was made in connection with the rebuilding of car engines to be refunded to the dealer upon delivery of a used engine of the same model. ... In this connection reference was made to a criminal law case of R v Hess (No 2), [1949] 4 DLR 199: The judgment of a competent Superior Court is a final adjudication in itself and Stands as such unless it is set aside on appeal. ...
FCTD
Al Telbani v. Canada (General Attorney), docket T-973-08
“participant” « participant » “participant” means a person who, in connection with a proceeding, is required to disclose, or expects to disclose or cause the disclosure of, information. ... (3) An official, other than a participant, who believes that sensitive information or potentially injurious information may be disclosed in connection with a proceeding may notify the Attorney General of Canada in writing of the possibility of the disclosure, and of the nature, date and place of the proceeding ... [...] 38.02 (1) Subject to subsection 38.01(6), no person shall disclose in connection with a proceeding (a) information about which notice is given under any of subsections 38.01(1) to (4); (b) the fact that notice is given to the Attorney General of Canada under any of subsections 38.01(1) to (4), or to the Attorney General of Canada and the Minister of National Defence under subsection 38.01(5); (c) the fact that an application is made to the Federal Court under section 38.04 or that an appeal or review of an order made under any of subsections 38.06(1) to (3) in connection with the application is instituted; or (d) the fact that an agreement is entered into under section 38.031 or subsection 38.04(6). [...] 38.04 (1) The Attorney General of Canada may, at any time and in any circumstances, apply to the Federal Court for an order with respect to the disclosure of information about which notice was given under any of subsections 38.01(1) to (4) ...
FCTD
S Madill LTD (Formerly Named Madill Sales Ltd) v. Minister of National Revenue, [1972] CTC 47, 72 DTC 6027
In that connection the income tax return of the old sales company for 1967 shows commissions earned in the amount of $112,139, as compared with $169,232 in 1966. ... He said that because of the sales contract Wilfert consulted with him in connection with the products available for sale and as to their prices and other matters in that respect, but that Wilfert and Smith played no part in running the company, except for such activities as they performed as directors. ... Smith said that he was a silent partner in the running of the old sales company, but he had discussions with Wilfert in connection with the investing of the company’s money and he advised that the company purchase shares of the old manufacturing company, because they were a good investment. ...
FCTD
Varennes Holdings Corp. v. R., [1975] C.T.C. 230, 75 D.T.C. 5164
He stated that land has to be bought some time in advance and frequently is not serviced at the time it is bought and, in fact, lengthy negotiations have to be entered into with the municipalities in connection with zoning and services. ... The Louis Hippolyte Lafontaine tunnel joining the east end of Montreal to the south shore as part of the Trans-Canada Highway was not built until about 1966 or 1967 and the Metro connection to the south shore via St Helen's Island was only built just prior to Expo 67. ... Water connections would be within about a mile of subject property. In 1968 to 1970 water was furnished for Hydro Quebec which was 5 miles distant. ...
FCTD
Lizotte, Re, 2003 FC 1509, 2003 FC 1508
Garnishee REASONS FOR ORDER AND ORDER [1] This is an ex parte motion by the Deputy Minister of Revenue of Quebec that the Court issue a garnishee order to show cause for the purpose of attaching all of the judgment debtor's amounts payable or to become payable on the dividends or on any other amounts connected with the holding of shares owing to him by the garnishee. [2] This motion is dismissed without prejudice to the judgment creditor's right to file another motion because the affidavit in support of this motion does not establish any connexion between the judgment debtor and his shareholdings in the garnishee. [3] Moreover, the exemption from notice that the judgment creditor seeks under rule 395 of the Federal Court Rules, 1998, is not at all justified and documented in the same affidavit that was submitted. [4] Finally, the draft order attached to the motion at bar does not address the state in which the garnishee's shares are held in a specific and limited manner. [5] The judgment creditor, like his federal counterpart, must approach garnishment proceedings in this Court with careful attention to detail in preparing his motion records. ...
FCTD
Millette v. Revenu Canada, [1999] 4 CTC 341, 99 DTC 5474
Additionally, Parliament has not authorized the Crown, in the course of a seizure made pursuant to s. 224 of the Income Tax Act, to observe immunity from seizure pursuant to a provincial statute, as it actually did in connection with a seizure of movable property under s. 225(5). ...