Search - connection

Results 61 - 70 of 1090 for connection
FCTD

Shilling v. Minister of National Revenue, 99 DTC 5441, [1999] 3 CTC 415 (FCTD)

Shilling argued that residence on a reserve may serve to prove a connection to a reserve, but residence off reserve cannot prove the contrary. ... In my view this is not correct, because it does not recognize the need for a connection to the reserve as a physical place. ... Her work benefits AHT, a Toronto organization with significant connections to various reserves, and of course the clientele of AHT. ...
FCTD

Shilling v. Canada, docket T-222-97

Shilling argued that residence on a reserve may serve to prove a connection to a reserve, but residence off reserve cannot prove the contrary. ... In my view this is not correct, because it does not recognize the need for a connection to the reserve as a physical place. ... Her work benefits AHT, a Toronto organization with significant connections to various reserves, and of course the clientele of AHT. ...
FCTD

The Queen v. E. V. Keith Enterprises Ltd., 76 DTC 6018, [1976] CTC 21 (FCTD)

Gray and Quilley were professional golfers; the loans to them were to finance the stock in trade for a pro shop at a private golf course which the defendant developed in connection with a residential sub-division in which it was interested. ... It had, on previous occasions, given the accommodation to the individual principals of the actual business connection. ...
FCTD

CBS/Fox Co. v. The Queen, 95 DTC 5631, [1996] 1 CTC 3 (FCTD)

Those provisions read as follows: 212(5) Every non-resident person shall pay an income tax of 25 per cent 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 satisfaction of, payment for a right in or to the use of (a) a motion picture film, or (b) a film, video tape or other means of reproduction for use in connection with television (other than solely in connection with and as part of a news program produced in Canada), that has been or is to be used or reproduced in Canada. ...
FCTD

Corporation xprima.com v. IXL Marketing inc., 2011 FC 624

  [2] Considering the case history and the five orders or instructions of the Court allowing an alternative mode of service, the instruction concerning costs and the documents produced in connection with the taxing of the bill of costs were posted in the registries of the local offices of the Federal Court in Montreal and Quebec City, and were also sent to the defendants by regular mail and registered mail. ... In connection with the Court’s decisions on each of these requests, none mentions the award of costs or states to whom, if there were any, they would be awarded. ...
FCTD

Scipion v. Canada (Citizenship and Immigration), 2019 FC 1497

Scipion does not have the profile of a woman without foundation, without connections, without a home and without a male presence. ... Scipion submits that the RAD erred because (1) not knowing one’s assailants does not mean that she was not targeted by assailants or that the assailants did not know her; (2) the fact that the assailants wore masks does not mean that they would not have an interest or reason to attack her mother or her; (3) the fact that she was attacked at her home means she was targeted; (4) a generalized risk and a personalized risk are not mutually exclusive; (5) having a home, connections and a male presence in Haiti does not guarantee effective assistance or protection to those in need; and (6) the RAD seems to contradict itself in paragraph 52 where it wrote that the applicant faces more than mere possibility of being persecuted and in paragraph 53 where it wrote that the applicant did not establish a well-founded fear of persecution by reason of her gender. [7]   Ms. ...
FCTD

Her Majesty the Queen v. Georges E Lemay, [1980] CTC 202, 80 DTC 6137

A similar appeal was made in connection with the taxation of costs in the same amount in case No T-249-77 Her Majesty The Queen and Doctor Claude Leclerc. ... Although judgment was rendered in favour of plaintiff maintaining the tax appeals in each case plaintiff was required to pay defendants “reasonable and proper costs” pursuant to the provisions of paragraph 178(2)(a) of the Act which reads as follows: Where, on an appeal by the Minister, other than by way of cross-appeal, from a decision of the Tax Review Board, the amount of (a) tax, refund or amount payable under subsection 196(2) (in the case of an assessment or determination, as the case may be) that is in controversy does not exceed $2,500, the Federal Court, in delivering judgment disposing of the appeal, shall order the Minister to pay all reasonable and proper costs of the taxpayer in connection therewith. ...
FCTD

Her Majesty the Queen v. Thomas Healy, [1978] CTC 355, 78 DTC 6239

In 1973 the defendant was employed during the thoroughbred racing season from March 21 to December 1 as a money room division head and at times as a money room captain, all in connection with the pari mutuel operations of the Club. ... Under subsection 178(2) of the Income Tax Act, the Minister of National Revenue will be ordered to pay all reasonable and proper costs of the defendant in connection with the appeal. ...
FCTD

Mikoula v. Canada (Attorney General), 2023 FC 678

To set aside a decision on the basis that it is unreasonable, the reviewing court must be satisfied that “ there are sufficiently serious shortcomings in the decision such that it cannot be said to exhibit the requisite degree of justification, intelligibility and transparency ” (Vavilov at para 100). [9] It is apparent from the second reviewer’s case notes as well as her affidavit filed in connection with this application for judicial review that her concern was not whether the applicant’s stated income qualified her for the CRB but, rather, whether she had actually received that income. ... She also knew that the applicant had reported this income to Service Canada in connection with her application for Employment Insurance benefits and that her receipt of these benefits was delayed as a result. ...
FCTD

Yarmouth Industrial Leasing Ltd. v. The Queen, 85 DTC 5401, [1985] 2 CTC 67 (FCTD)

A certain amount of paper work was done in connection with preparations for carrying on the equipment leasing business. ... It is instructive to look at Interpretation Bulletin IT-376 in this connection, paragraph 7 of which reads as follows: Whether the corporation carried on "That business” is a question of fact. ... In further support of these conclusions it should be noted that subsection 111(1) is a deduction section, with paragraph 111(5)(a) setting forth the conditions under which deduction cannot be made, and it is constantly held that a deduction section must be strictly construed against the taxpayer, (see for example in this connection the case of Lumbers v MNR, [1943] Ex CR 202; [1943] CTC 281). ...

Pages