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Results 521 - 530 of 1092 for connection
FCTD

DeLuca v. The Queen, 87 DTC 5202, [1987] 1 CTC 305 (FCTD), aff'd 91 DTC 5540 (FCA)

“Canadian resource property” of a taxpayer means any property acquired by him after 1971 that is, (i) any right, licence or privilege to explore for, drill for, or take petroleum, natural gas or other related hydrocarbons in Canada, (ii) any right, licence or privilege to prospect, explore, drill, or mine for minerals in a mineral resource in Canada, (iii) any oil or gas well situated in Canada, (iv) any rental or royalty computed by reference to the amount or value of production from an oil or gas well, or a mineral resource, situated in Canada, (v) any real property situated in Canada the principal value of which depends upon its mineral resource content (but not including any depreciable property situated on the surface of the property or used or to be used in connection with the extraction or removal of minerals therefrom), or (vi) any right to or interest in any property (other than property of a trust) described in any of subparagraphs (i) to (v) (including a right to receive proceeds of disposition in respect of a disposition thereof); 66.2 (1) A taxpayer shall include, in computing the amount referred to in paragraph 59(3.2)(c), the amount, if any, by which (a) the aggregate of all amounts referred to in subparagraphs (5)(b)(iv) to(ix) that would be taken into account in computing his cumulative Canadian development expense at the end of the year exceeds (b) the aggregate of all amounts referred to in subparagraphs (5)(b)(i) to (iii) that would be taken into account in computing his cumulative Canadian development expense at the end of the year Generally, these provisions of the Income Tax Act reflect the special tax treatment accorded to resource properties under the Act. ...
FCTD

Picadilly Hotels Ltd. v. The Queen, 78 DTC 6444, [1978] CTC 658 (FCTD)

Paragraph 11 (1)(e) is as follows: 11. (1) Notwithstanding paragraphs (a), (b) and (h) of subsection (1) of section 12. the following amounts may be deducted in computing the income of a taxpayer for a taxation year: (e) a reasonable amount as a reserve for (i) doubtful debts that have been included in computing the income of the taxpayer for that year or a previous year. and (ii) doubtful debts arising from loans made in the ordinary course of business by a taxpayer part of whose ordinary business was the lending of money; In Harlequin Enterprises Ltd v The Queen, [1974] CTC 838; 74 DTC 6634, affirmed [1977] CTC 208; 77 DTC 5164, Mahoney, J said: This deduction was sought in an appeal to the Income Tax Appeal Board in respect of its 1949 income tax assessment by a taxpayer with which the present plaintiff may have had some connection. ...
FCTD

Porta-Test Systems Ltd. v. The Queen, 80 DTC 6046, [1980] CTC 71 (FCTD)

This is evident from the various dictionary definitions of the word “Royalty” when used in connection with a sum payable. ...
FCTD

Jacobson Holdings Ltd. v. The Queen, 85 DTC 5634, [1986] 1 CTC 87 (FCTD)

., [1984] C.T.C. 2005; 84 D.T.C. 1752 where it was said that acceptance by the Minister of expenses incurred in connection with the use of land as a “restricted farming loss” amounted to an admission that the land in question was being used as a capital asset in a business. ...
FCTD

Templeton v. R., 97 DTC 5216, [1998] 3 CTC 207 (FCTD)

During the period of his residency in Penetanguishene the Plaintiff was frequently required to travel to Toronto in connection with his activity as broadcaster-commentator for radio station CKEY. 3. ...
FCTD

Nova Ban-Corp Ltd. v. Tottrup, 89 DTC 5489, [1989] 2 CTC 304 (FCTD)

In Canada that confidentiality is required, in circumstances such as the present, by subsection 241(2) of the Income Tax Act which states that no official shall be required in connection with any legal proceedings to testify as to informa tion obtained on behalf of the Minister for the purposes of the Act. ...
FCTD

Friedland v. The Queen, 89 DTC 5341, [1989] 2 CTC 79 (FCTD)

The next day, Dominion severed their connection with him. A well known counsel, Austin Cooper, was instructed to defend. ...
FCTD

Livingston International Inc. v. Canada (Minister of National Revenue), docket T-1953-87

Justice Rand stated, at p. 726: No doubt there is in fact a causal connection between the purchase of the stock and the benefits ultimately received; but the statutory language cannot be extended to such a remote consequence; it could be carried to any length in a chain of subsidiaries; and to say that such a thing was envisaged by the ordinary expression used in the statute is to speculate and to interpret. ...
FCTD

Canada (Minister of National Revenue) v. McMordie, 2006 FC 209

The Respondent's failure was by not having provided a list of all of the Canadian and foreign institutions which held accounts for which he had signing authority or power of attorney and, in connection therewith, the account holders, the account numbers and the dates the accounts were opened and closed as well as a list of the names of the credit cards, the names of the issuers of those cards, their account numbers that were in his name, in the name of his business or in which the Respondent was a joint holder. [7]                The Respondent testified to the effect that he had substantially complied with the order because if one examined his several responses and his final response on April 16, 2005, the banks were identified as well as the credit cards and their issuers. [8]                However, in argument, he admitted his responses lacked several details which he was required to provide. [9]                Based on the evidence before me and the Respondent's admission I am satisfied beyond a reasonable doubt that the Respondent is guilty of contempt by failing to wholly provide the Minister the information/documents spelled out in items 2 and 4 of counsel to the Minister's letter of February 23, 2004, to Justice MacKay and which were the acts specified in Prothonotary Lafrenière's Show Cause Order of December 19, 2005. [10]            The penalty which the Court may impose on a finding of contempt is spelled out in Rule 472 which reads: 472. ...
FCTD

Canada (Canada Customs and Revenue Agency) v. Sherman, 2006 FC 192

Accordingly, I am convinced this is not a case where I should decline to exercise my discretion. [9]                It is perhaps of some significance that in early 2000 the Respondent initiated a complaint to the Canadian Human Rights Commission (Tribunal) in connection with her treatment by the CCRA with particular reference to the issues of accommodation and termination. ...

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