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FCTD

Holden Wild Rice Limited v. Her Majesty the Queen, [1977] CTC 76, 77 DTC 5064

Merrick George Holden of the Village of Lac du Bonnet in Manitoba, president of the plaintiff company, gave a brief outline of his and the company’s experience in connection with wild rice. ... These are two forms of receipt drawn up in connection with the transaction, and apparently intended to comply with the requirement of clause 5 of the agreement of March 27, 1970. ...
FCTD

Nathaniel C Brewster v. Her Majesty the Queen, [1976] CTC 107, 76 DTC 6046

And, it contains an admission concerning the reassessment for the 1969 taxation year and adds, “That the Plaintiff was also assessed for his 1970 and 1971 taxation years in connection with the same transaction”. ... Mr Ward: I reserve until 1 find out what connection there might be amongst the various subparagraphs in which there might be more clarity, as to your answer as to what! ...
FCTD

Lawrence H Mandel/ v. Her Majesty the Queen, [1976] CTC 545, 76 DTC 6316

An agreement dated February 1, 1973 between Canadian Film Development Corporation, Amaho Limited referred to as the assignee, Topaz Productions Limited, Niagara Television Limited, Robert Lawrence Productions Limited, John T Ross, and One Flag Under Ontario Investments Limited & Film Associates and Alexis Kanner, sets out that Niagara provided financing of the film in the amount of $125,000 and paid a further sum of approximately $10,000 in connection with the completion of it. ... Lord Reid stated at page 858: No doubt the words “liability” and “contingent liability” are more often used in connexion with obligations arising from contract than with statutory obligations. ...
FCTD

Canadian Pacific Railway Company v. Canada, 2021 FC 1014

(ii) The historical context of the 1880 Contract and Clause 16 [152] To determine the legal status of Clause 16, I must consider the historical context in which the 1880 Contract was signed, including its connection to the BC Undertaking. ... The Defendant is not entitled to collect tax imposed under Part 1 of the ITA on income earned by CPRC in connection with the operation of the Canadian Pacific Railway (as defined in paragraph 9 of this Statement of Claim) since such taxes are ultra vires; D. The Defendant is not entitled to collect Carbon Taxes imposed under Part 1 of the GGPPA, in connection with the operation of the Canadian Pacific Railway (as defined in paragraph 9 of this Statement of Claim) since such taxes are ultra vires. [740] The second and third declarations no longer apply, as I have determined that Clause 16 does not exempt Income or Fuel Tax. ...
FCTD

384238 Ontario Ltd. v. The Queen, [1981] CTC 295, 81 DTC 5215 (FCTD), aff'd 84 DTC 6101 (FCA)

The Queen, [1981] CTC 295, 81 DTC 5215 (FCTD), aff'd 84 DTC 6101 (FCA) Walsh, J:—This action arises out of the seizure in the hands of plaintiff companies of certain assets allegedly belonging to them for income tax and other tax arrears owed by one Kenneth Richard Allen and a company owned and operated by him and/or his wife Emily Allen known as Ken Allen and Sons Limited, the said assets consisting primarily of purebred Percheron show horses and farm equipment required in connection with the maintenance and showing at exhibitions of the said horses. ... He carried on the business on owned and rented farms in Markdale, Ontario, using the name Allendale Farms in connection with his horse breeding business which appears to have been successful. ... He testified that he had been working on the farm and this was given to him in compensation, and that he had had some help from his mother in connection with the cash payment at the time. ...
FCTD

Olympia Interiors Ltd. v. Canada, docket T-1436-92

Martin to inform him that she would not provide the contracts, which were in Calgary in connection with litigation there. ... Canada 18, that there are three essential elements to the tort of conspiracy: an agreement to cause damage to another person, a concerted action carried out in pursuance of that agreement and actual economic damage resulting from a direct causal connection to that action. [79]      In Canada Cement LaFarge Ltd. v. ... I have referred to this earlier but in this connection there simply was not evidence before me of the prejudice claimed by the plaintiffs. ...
FCTD

Committe for Monetary and Economic Reform v. Canada, 2014 FC 380

  [18]            Prothonotary Aalto also found that s.7 of the Charter was not engaged because no causal connection was pleaded between the impugned Government economic policies and actions and an infringement of the right to life, liberty and security of the person. ...   [59]            The Defendants argue that the Prothonotary was right to conclude that there is no causal connection pleaded connecting the impugned Government economic policies and actions to a breach of s. 7. Nor are there any “evidentiary facts” pleaded, whether “real or intangible” (see Operation Dismantle Inc, above, at para 78), that could establish such a causal connection, and no real possibility of establishing such facts. ...
FCTD

Tippett v. Canada, 2019 FC 869

The Statement of Claim seeks damages including punitive damages. [10]   The present motion seeks an order certifying this action as a class action and granting an order with certain contents under Rule 334.17 in connection with such certification. ... Many of the witnesses interviewed in connection with the investigation were canvassed as to their knowledge of those circumstances. ... It is therefore unnecessary, in connection with this particular determination, to consider the Plaintiff’s argument that an adverse inference should be drawn from the Defendant’s decision not to file an affidavit in this motion. [53]   However, the Plaintiff also advances the adverse inference argument in relation to the definition of the class. ...
FCTD

Olympia Interiors Ltd. v. R., [1999] 3 CTC 305

Martin to inform him that she would not provide the contracts, which were in Calgary in connection with litigation there. ... Canada^, [18] that there are three essential elements to the tort of conspiracy: an agreement to cause damage to another person, a concerted action carried out in pursuance of that agreement and actual economic damage resulting from a direct causal connection to that action. ... I have referred to this earlier but in this connection there simply was not evidence before me of the prejudice claimed by the plaintiffs. ...
FCTD

Coopers & Lybrand Ltd., Trustee of Hawboldt Hydraulics (Canada) Inc. v. The Queen, 92 DTC 6452, [1992] 2 CTC 363 (FCTD)

., a chemical fertilizer) who also provided a service in connection therewith (e.g., spreading the fertilizer for his customers) would be denied the processing tax deduction. ...

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