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Results 941 - 950 of 1093 for connection
FCTD
Indalex Ltd. v. The Queen, 84 DTC 6018, [1984] CTC 51 (FCTD), aff'd on other grouns 84 DTC 6492, [1984] CTC 373 (FCA)
V R Johnson became managing director of Pillar International Services Limited on August 1, 1973 and took part in negotiations with Alcan in 1974 and 1975, and later in connection with the termination by Indalex Limited at the end of 1976 of its purchasing contract with Pillar International Services Limited. ...
FCTD
Vancouver Trade Mart Inc. (Trustee Of) v. Canada (Attorney General), 97 DTC 5520, [1998] 1 CTC 79 (FCTD)
At 5283, he put it as follows: Applying these principles, as I understand them, to materials prepared by accountants, in a general way, it seems to me (a) that no communication, statement or other material made or prepared by an accountant as such for a business man falls within the privi lege unless it was prepared by the accountant as a result of a request by the business man’s lawyer to be used in connection with litigation, existing or apprehended; and (b) that, where an accountant is used as a representative, or one of a group of representatives, for the purpose of placing a factual situation or a problem before a lawyer to obtain legal advice or legal assistance, the fact that he is an accountant, or that he uses his knowledge and skill as an accountant in carrying out such task, does not make the communications that he makes, or participates in making, as such a representative, any the less communications from the principal, who is the client, to the lawyer; and similarly, communications received by such a representative from a lawyer whose advice has been so sought are none the less communications from the lawyer to the client. ...
FCTD
McClain Industries of Canada Inc. v. The Queen, 78 DTC 6356, [1978] CTC 511 (FCTD)
As to what transpired at this meeting in connection with the liability or potential liability of the company for $60,000 accrued management commissions disclosed in the financial statement, or more correctly the balance of $41,535.95 since $18,464.05 had been paid out, on closing is the subject of conflicting testimony. ...
FCTD
Mister Muffler Ltd. v. The Queen, 74 DTC 6615, [1974] CTC 813 (FCTD)
In the present case the replacement of mufflers can clearly be claimed as an expense in the year in which the replacement takes place but the probability of this being necessary in connection with one-fifth of all the mufflers sold, and even the fact that plaintiff has charged extra for the original muffler to allow for this, does not in my view permit the deduction of a reserve in the year in which the original sale was made even though this may be good accounting practice. ...
FCTD
Canada v. Folster, 97 DTC 5315, [1997] 3 C.T.C. 157 (FCA)
When: (i) the employer is resident on a reserve; and (ii) the employer is: (a) an Indian band which has a reserve, or a tribal council representing one or more Indian bands which have reserves, or (b) an Indian organization controlled by one or more such bands or tribal councils, if the organization is dedicated exclusively to the social, cultural, educational, or economic development of Indians who for the most part live on reserves; and (iii) the duties of the employment are in connection with the employer's non-commercial activities carried on exclusively for the benefit of Indians who for the most part live on the reserves; all of the income of an Indian from an employment will usually be exempt from income tax. ...
FCTD
Harlequin Enterprises Ltd. v. The Queen, 74 DTC 6634, [1974] CTC 838 (FCTD), aff'd 77 DTC 5164, [1977] CTC 208 (FCA)
This deduction was sought in an appeal to the 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
Venne v. The Queen, 84 DTC 6247, [1984] CTC 223 (FCTD)
I do not find that high degree of ‘negligence in connection with the misstatements of business income. ...
FCTD
Malka v. The Queen, 78 DTC 6144, [1978] CTC 219, [1978] CTC 219 (FCTD)
II Extending the powers of the Company as set forth in the Letters Patent by adding the following powers: (i) To manufacture, import, export footwear, clothing and other related objects; (ii) To carry on the business of general manufacturers; (iii) To establish shops and stores and to purchase, sell and deal in all kinds of goods, wares and merchandise in connection with the operations of the Company. ...
FCTD
Gibralter Mines Ltd. v. The Queen, 85 DTC 5085, [1985] 1 CTC 116 (FCTD)
In this connection it is important to note that the total amount of royalty thus calculated by Gibraltar for the period January 1 to May 6, 1974 is substantially in excess of the total amount of royalty which was payable for the whole year. ...
FCTD
Marsted Holdings Ltd. v. The Queen, 86 DTC 6200, [1986] 1 CTC 436 (FCTD)
In my view, this term does no more than refer to a practical approach for determining certain questions that arise in connection with “trading cases” but there is no principle of law that is represented by this tag. ...