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Results 71 - 80 of 1090 for connection
FCTD
Dorey v. Canada (Customs and Revenue Agency), 2003 FC 1241
SUBMISSIONS [12] The Applicant's main argument is that he was never notified of an obligation to file an annual information return in connection with payment of the withholding tax. He says that in the absence of notice to him about filing this form, he should not be penalized, in any way for the late filing of the form, especially since all taxes in connection with the rent paid by the non-resident, have been paid. ... Justason in connection with the third request. The Applicant says this reliance was improper because the agents of the Respondent had not followed their own procedures in reaching a determination of the second request. ...
FCTD
Bhuiyan v. Canada (Citizenship and Immigration), 2019 FC 1518
She did not tell the Board Member that she would not be able to live in Chittagong because of poor internet connection. ... She was unable to move to any village where internet connection was poor. ... So without this kind of internet connection, I cannot conduct my business. ...
FCTD
Montreal Aluminium Processing Inc. And Albert Klein v. Attorney General of Canada and Minister of National Revenue, [1991] 2 CTC 70, 91 DTC 5424
Analysis With all due respect for the able arguments put forth by counsel for the plaintiff, I believe that section 231.2 of the Income Tax Act, when read in conjunction with Article XXVII of the Convention and section 3 of the Tax Convention Act, does give the Minister the power to issue a requirement for information sought by U.S. authorities in connection with their own taxation matters. ... Secretary of the Treasury wants the information for use in connection with Grand Jury proceedings not solely related to the violation of U.S. tax laws. ... This Article prevents information provided by the Minister to U.S. authorities from being used otherwise than in connection with the administration and enforcement of U.S. taxation laws. ...
FCTD
Danzas (Canada) Ltée and Danzas S.A. v. Her Majesty the Queen in Right of Canada, [1986] 1 CTC 174
The Lufthansa case involved an importer known as Rossignol Diffusion, and the only connection that could be made with the protagonists in the case at bar is that both cases involved Mirabelle Courtiers en Douanes Ltée. ... In fact, the R.C.M.P. heard nothing more of the matter until the events of April 11, 1980, which suggested a connection and indicated that the same international smuggling ring was involved. ... It should be noted in this connection that the evidence did not show that any customs officer besides Chevrier was aware of the notice and failed to inform his employer or the R.C.M.P. ...
FCTD
Canadian Wirevision Limited v. Her Majesty the Queen, [1978] CTC 69, 78 DTC 6113
The definition of “qualified activities” in regulation 5202 has some relevance: “qualified activities” means (a) any of the following activities, when they are performed in Canada in connection with manufacturing or processing (not including the activities listed in subparagraphs 125.1 (3)(b)(i) to (ix) of the Act) in Canada of goods for sale or lease: (i) engineering design of products and production facilities, (ii) receiving and storing of raw materials, (iii) producing, assembling and handling of goods in process, (iv) inspecting and packaging of finished goods, (v) line Supervision, (vi) production support activities including security, cleaning, heating and factory maintenance, (vii) quality and production control, (viii) repair of production facilities, and (ix) pollution control, (b) all other activities that are performed in Canada directly in connection with manufacturing or processing (not including the activities listed in subparagraphs 125.1 (3)(b)(i) to (ix) of the. ... We request that the 1974 appeal, to the extent it relates to the treatment of drop line connection costs, be allowed and the matter be referred back to the Minister of National Revenue for reassessment in terms whereby exterior costs, namely, those relating to drop lines connecting cablevision cables with single family dwellings or with the central meter or core areas of multiple occupancy buildings, such as apartments, which amount to 25% of total connection costs, be treated as outlays upon capital account and interior costs, being those relating to drop lines from the outside of single family dwellings or from the meter or core areas of multiple occupancy buildings to individual television sets in suites or otherwise, which amount to 75% of total connection costs, be allowed as expenses. ...
FCTD
Her Majesty the Queen v. Stanfold Investment Corporation, [1974] CTC 19, 74 DTC 6035
He had known Mr Berman since about 1959 in connection with other property which Mr Berman owned some three miles away which was being developed by Mr. ... The fourth and only other land operation of the company was in connection with the St-Martin property. ... In the present case defendant did nothing whatsoever in connection with maturing or disposing of the property with a view to sale of same. ...
FCTD
Bekkai v. Canada (Attorney General), 2024 FC 981
Statement for RBC bank account--------- between December 2018 and November 2021. 2. 2019–20 expenses With respect to the CERB, the notes read as follows: [translation] Explain your decision regarding each criterion that was not met: CONNECTION TO COVID: The TP [taxpayer] is self-employed and has worked for the UBER, SKIPDISHES, FOODORA and DOORDASH food delivery companies since at least December 2018. ... As a result, the income reduction has no connection to COVID. CONNECTION TO COVID: The TP did not work during some periods, but this was a personal choice, and he is therefore not eligible because he did not work for reasons other than COVID. ... The connection could not just be temporal; the reductions had to be related to COVID‑19. [18] But the administrative decision maker concluded that the applicant had ceased being self-employed for reasons that were not related to COVID-19 but rather personal reasons that likely coincided with the replacement income he could receive under the available government programs. [19] The applicant’s argument consists of claiming that there had been a focus on the reduction in weekly income. ...
FCTD
The Queen v. Lavigueur, 73 DTC 5538, [1973] CTC 773 (FCTD)
Mr Rainu approached Messrs Bolduc and Lavigueur explaining that they had used all their funds in connection with the building of the prototype and did not even have sufficient money for the week’s payroll but hoped to obtain the necessary approval and commence production at an early date. ... The procedure adopted in connection with the 29 loans made following March 6, 1967 was for Messrs Bolduc and Lavigueur to issue a cheque to Radal Limited which was then deposited in its account and the bank presented the company with a note for signature. ... If this interpretation is accepted this subsection of the Act in question then requires the Minister to pay ‘‘all reasonable and proper costs of the taxpayer in connection therewith”. ...
FCTD
Lakeview Gardens Corp. v. MNR, 73 DTC 5437, [1973] CTC 586 (FCTD)
If we had been dealing with a capital sum paid to acquire these shares this would clearly have been an oui’ay or expense in connection with property (ie the shares) the income of which would be exempt. ... It paid $124,000 in round figures for the shares in 1962 and undertook to pay an additional $50,000 by means of a promissory note which did not, however, bear interest, so no interest expense was incurred by appellant in connection with this note. ... On the whole it appears that appellant never expended more than $124,000 in connection with this investment and of this sum it received back $38,000 in 1965 from the liquidation of the company. ...
FCTD
Her Majesty the Queen v. Pollock Sokoloff Holdings Corp, [1974] CTC 391, 74 DTC 6321
The explanation given by witnesses in testimony was that no formal loan agreement was drawn up in connection with the last loan because Mr Crystal had no further assets to pledge and it was felt, in any event, that the substantial assets of the real estate companies in which he had already pledged his shares as security for the first two loans was sufficient guarantee for the third loan also. ... The companies were so interchangeable in his mind that he found nothing unusual, for example, in Pollock Sokoloff issuing the $10,000 cheque to Mr Crystal in connection with the third loan although same had been made by Mysam. Similarly, an account from the companies’ solicitor rendered to Mysam for legal services in connection with the eventual bankruptcy of Mr Crystal in 1969 was paid by Pollock Sokoloff as Mr Lipper, one of their attorneys, testified. ...