Search - connection

This is one of those fine line questions between seeking evidence and questions aimed at getting the witness to divulge relevant facts in connection with an allegation. ... Again, I can see some possible relevance, certainly in connection with the penalty issue: this request should be answered.   42.              ... Duan, in connection with his expert opinion in this matter, they should be provided.   49.              ...

Instead they went to people with whom Harold Coombs had a close connection. ... They all had very little connection with the charity, and were not so wealthy that a gift of this nature would be expected. ... Russell had no, or very little, connection with the charity and gave no credible explanation for these very large donations. ...

(g)                 While auditing the Appellant's books, the Minister's auditor noticed that, in computing its net tax, the Appellant, starting in 2001, had been claiming undocumented ITCs in connection with supplies purportedly received from Ferblanterie Alexandre and D.H.  ... (m)               As for the invoices submitted in connection with the ITCs claimed on supplies purportedly received from D.H.  ... (ff)                During the audit, the Minister's auditor therefore disallowed ITCs claimed by the Appellant in connection with the invoices purportedly issued by St-Isidore.   ...

He presented an analysis of the losses suffered by Abeille Ré in connection with the two bailout agreements described above. ... Lessard was asked to prepare a report dated June 30, 1993, on the situation with respect to reserves in connection with the agreement of September 30, 1990. ... In late 1992, it was believed in Paris that the losses in connection with this investment exceeded $100 million. ...

With respect to the last guideline, Revenue Canada observed that:... in the case of non-commercial activities of a band or tribal council representing Indians on a reserve or an organization controlled by one or more of these entities and dedicated to the social, political, economic or cultural development of those Indians which is resident on a reserve, it is reasonable to conclude that there is sufficient connection to a reserve to warrant an exemption. ... Emphasis added With respect to each of the foregoing examples, it was the position of Revenue Canada that sufficient connection would exist to a reserve to locate the income there and grant the tax exemption. [8] [22] On March 7, 1994, the Assistant Deputy Minister, Legislative & Intergovernmental Affairs Branch, Revenue Canada, wrote to the Awasis agency confirming that its employees were not exempt from income tax on their employment income because: As you know, draft guideline # 4 requires an organization to meet various criteria in order for its employees to be tax exempt. ... In these circumstances, giving much weight to the situs of the employer as a connecting factor would be less than satisfactory in achieving the legislative purpose behind the section 87 tax exemption. [29] I turn next to the connection between Awasis and the reserves it serves as well as the manner in which that employment benefited the reserves. ...

In connection with that research, he had to hire an assistant at a cost of $400. ... Lallier included money received in connection with various activities, such as teaching. ... In respect of the work as a lecturer, he claimed to be self-employed and to be entitled to deduct expenses of $709 in connection therewith. ...

Factor 8 – The Relationship/Connection between Counsel, the Prospective Witness and the Parties Involved in the Litigation: [49]         There are two connections at play that raise concern. ... Mamdani is a former associate with the firm, his precise present connection with Appellant counsel is unknown as there appears to be a continuation of strong links between this individual and Appellant counsel’s law firm. ... When counsel of record has the type of intricate “connection” to a witness, as in this case, there can be no assurances to the court, the public or the client that counsel, in fact and in appearance, will act objectively in those duties. ...

The Minister disallowed the Corporation's claim for net expenditures in its 1993 and 1994 taxation years in the amounts of $39,347 and $51,034, respectively, in connection with its Firearms Division. ... Thus, if as a matter of fact a taxpayer is found not to have a reasonable expectation of profit, then there is no business and the taxpayer cannot claim any expenses in connection with that activity. [29]          When reviewing whether there is an expectation of profit and there is determined to be a personal element involved, Linden J.A. of the Federal Court of Appeal stated in Tonn v. ... No such analysis was given. [46]          The Corporation deducted investment tax credits in respect of qualified expenditures for SRED in connection with its 1993 and 1994 taxation years. ...

This connection between Allind and LBL caused the CRA to believe that LBL may also have been selling tobacco products in non-compliance with the Act. ... It appears that LBL is simply asking for the contact information of anyone who had any connection with the case, no matter how remote, in the hope that it can find some beneficial piece of information. ... Subsection 95(4) of the Rules does not entitle taxpayers to the contact information of every person who had any connection with their file no matter how remote. ...

The taxable portion of the capital gain must be reported by the limited partner like all other capital gains that may arise in connection with the disposition of a partnership interest. ... A capital loss can then be realized in connection with the disposition of a separate property. ... In paragraph m) of the PASF, the Appellant acknowledges that its representative had discussions with its Tax Advisor and legal counsel to determine the best timing to generate two capital gains and an offsetting capital loss for the purpose of generating two increases in the Appellant’s CDA in connection with the sale of the Property while paying no tax on the Second Capital Gain. ...