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Results 951 - 960 of 1093 for connection
FCTD
First Fund Genesis Corp. v. The Queen, 91 DTC 5361, [1991] 2 CTC 14 (FCTD)
Armstrong was in control of Dell by the time the second debenture was issued to the plaintiff and it is his name that appears on the closing documentation prepared in connection with the May 23, 1985 transaction. ...
FCTD
The Queen v. Kuhl, 74 DTC 6024, [1973] CTC 846 (FCTD)
My attention was directed to subsection 178(2) of the present Income Tax Act (RSC 1952, c 148, as amended by SC 1970-71-72, c 63) which provides that whenever, on an appeal by the Minister from a decision of the Tax Review Board, the amount of tax that is in controversy does not exceed $2,500, the Federal Court, in delivering judgment, shall order the Minister to pay “all reasonable and proper costs of the taxpayer in connection therewith”. ...
FCTD
Cal Investments Ltd. v. The Queen, 90 DTC 6556, [1990] 2 CTC 418 (FCTD)
In this connection the reader may be reminded that a seal "imports" both consideration and delivery: that is to say, where a contract is under seal it is not necessary to prove either consideration or the delivery of the contract, consideration not being necessary in the case of a contract under seal and delivery being presumed. ...
FCTD
Gulf Canada Ltd. [previously Gulf Oil Canada Ltd.] v. Her Majesty The Queen and Gulf Canada Resources Ltd. [previously Gulf Oil Canada Ltd.] v. Her Majesty The Queen, 90 DTC 6622, [1991] 1 CTC 99 (FCTD), aff'd 93 DTC 6123 (FCA)
"Canadian resource property" is defined in paragraph 66(15)(c) of the Act, as amended by S.C. 1974-75, c. 26, subsection 35(21), as follows: "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); If l comprehend the defendant's argument correctly, the point is that the lease rental payments were not made for the actual carrying out of exploration within the meaning of a Canadian exploration expense, but rather were payments for maintaining or preserving the right to carry out such activities, and therefore fall squarely within the terms of subparagraph 66.2(5)(a)(iii) of the Act. ...
FCTD
Buchanan Forest Products Ltd. v. The Queen, 86 DTC 6282, [1986] 2 CTC 7 (FCTD)
(a) To carry on in all and any of their branches the businesses of loggers, pulpwood cutters, lumbermen, lumber merchants and sawmill, planing-mill and pulpmill owners; (b) To buy, sell, prepare for market, manufacture, import, export and deal in pulpwood, sawlogs, timber, piles, poles, lumber and wood of all kinds and generally to carry on the business of lumbering and the lumber trade in all its branches; (c) To carry on the business of general manufacturers and to establish shops and stores, and to purchase, sell and deal in all kinds of goods, wares and merchandise; (d) To carry on the business of loading, unloading or transporting pulpwood, sawlogs, timber, piles, poles and any other goods, chattels or merchandise; (e) To construct roads and ways of every description; (f) To purchase or acquire and to hold and deal with lands and timber limits or licences; (g) To carry on the business of leasing trucks, bulldozers, power shovels and other types of heavy equipment; (h) To conduct and carry on the business of builders and contractors for the purpose of building, erecting, altering, repairing or doing any other work in connection with any and all classes of building and improvements of any kind and nature whatsoever, including the building, rebuilding, alteration, repair or improvement of houses, factories, buildings, works or erections of every kind and description whatsoever and the locating, laying out and construction of roads, avenues, docks, slips, sewers, bridges, wells, walls, canals and power plants and generally all classes of buildings, erections and works, both public and private, or integral parts thereof, and generally to do and perform any and all work as builders and contractors, and with that end in view to solicit, obtain, make, perform and carry out contracts covering the building and contracting business and the work connected therewith; and (i) For the objects aforesaid to acquire and take over as a going concern the partnership business and undertaking heretofore carried on in the said Improvement District of Red Rock and elsewhere in the said District of Thunder Bay by Kenneth Buchanan, John Buchanan, Frank McKenzie Buchanan and William Grenhall Buchanan under the name of Buchanan Brothers. ...
FCTD
Huet v. The Queen, 95 DTC 5008, [1995] 1 CTC 367 (FCTD)
Justice Rothstein of this Court stated, with respect to the argument that a retrospective taxing provision was contrary to section 7 of the Charter: The short answer to the section 7 argument is that there is no connection between the facts in this case and the right to life, liberty and security of the person. ...
FCTD
Shaw v. The Queen, 89 DTC 5194, [1989] 1 CTC 386 (FCTD), aff'd 93 DTC 5213 (FCA)
When you say “all other payments" in connection with the operation of the service station, does that include or does it not include the gallonage payments under the head lease? ...
FCTD
Axa Canada Inc. v. Canada (National Revenue), 2006 FC 17
We . . . do not see any direct connection with the federal tax existing on certain GST components, and moreover we consider that the expenditure of money was actually made, that the GST remains due on these amounts. ...
FCTD
Palonek v. Canada (Minister of National Revenue), 2006 FC 494
That is, the report prepared in connection with the Second Level Review specifically notes that neither Mr. ...
FCTD
Abbott Laboratories Ltd. v. Canada (Minister of National Revenue), 2004 FC 140
Le Clair that the law firm of Ogilvy, Renault was now authorized to act on behalf of Abbott in connection with the NAFTA review. [9] After reviewing the documents provided on Similac Infant formula (normal and advanced) on July 17, 2001, Ross Le Clair wrote to the exporter pursuant to subsection 42.2(1) of the Act to notify it of CCRA's intention to deny preferential tariff treatment for those two products. [10] Section 42.2(1) of the Act reads: 42.2 (1) On completion of a verification of origin under paragraph 42.1(1)(a), an officer designated under subsection 42.1(1) shall provide the exporter or producer whose goods are subject to the verification of origin with a statement as to whether the goods are eligible, under the Customs Tariff, for the preferential tariff treatment that was claimed. 42.2(2) Basis of statement (2) A statement referred to in subsection (1) must include any findings of fact or law on which it was based. ...