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Results 1021 - 1030 of 3269 for connection
TCC
Robert Verrier & Fils Ltée v. Minister of National Revenue, [1992] 2 CTC 2464, 92 DTC 2354
When the transaction expands the income structure of the purchaser's business (Sunstrum, para. 4.02(6)). 4.03.5 Because in this appeal there were two transactions concluded by the appellant and there is no connection between the two, they should be examined separately. 4.03.6 Transaction with Michaud, Gagné & Vallée Inc. 4.03.6 (1) In this transaction, the concurrent existence of certain elements such as the significant goodwill purchased, the transfer of the $80,000 insurance portfolio and the expansion of the income structure were key elements which incline the Court toward the respondent's position. 4.03.6(2) In Muller & Co.'s Margarine Ltd., (para. 4.02(13)), Lord Lindley made the following comments on the property [sic] between the concept of "goodwill" and that of "a going concern”, at page 235: Goodwill regarded as property has no meaning except in connection with some trade, business, or calling. In that connection I understand the word to include whatever adds value to a business by reason of situation, name and reputation, connection, introduction to old customers, and agreed absence from competition, or any of these things, and there may be others which do not occur to me. ...
TCC
Michel Gravel v. Minister of National Revenue, [1992] 1 CTC 2521, 92 DTC 1935
This limitation on the evidence prevents a litigant from proving facts which have no real connection with the litigation or which has no probative force, and which at the same time might create confusion, drag out the argument, or cause unnecessary prejudice to his or her adversary (Ibid., page 343). Lack of relevance is generally argued either because a fact has no connection with the litigation or because it has no probative force (Ibid., page 344). For one fact to be relevant to another, there must be a connection or nexus between the two which makes it possible to infer the existence of one from the existence of the other. ...
TCC
Tom Jj. Zeiben v. Minister of National Revenue, [1991] 2 CTC 2008, 91 DTC 886
—He claimed an investment tax credit and a refundable investment tax credit in connection with the acquisition of the new equipment. ... He then reassessed the Appellant for the 1984 to 1987 taxation years in the following manner: —He reduced to nil the taxable capital gain in connection with the trade-in of the used equipment. —He decreased the investment tax credit and the refundable investment tax credit in 1984 and 1986 in connection with the acquisition of the new equipment. ...
TCC
Doris J. Neville v. Minister of National Revenue, [1988] 2 CTC 2201, 88 DTC 1546
.: —This is an appeal heard in Ottawa, Ontario, on June 24, 1988, against an income tax assessment for the year 1985, in which the Minister of National Revenue disallowed an amount of $525 claimed by the taxpayer as part of the expenses in connection with her income as a commission sales person. ... Thus, the expenses in connection with any course which gives a credit towards a degree, diploma, professional qualification or similar certificate may not be deducted. On the other hand reasonable expenses in connection with a course which, for example enables a professional to learn the latest methods of carrying on his profession are allowable. ...
TCC
Woodlin Developments Ltd. v. Minister of National Revenue, [1986] 1 CTC 2188, 86 DTC 1116
The second recital reads: AND WHEREAS the parties hereto desire to define and record by this Agreement as between themselves their respective interests and obligations in connection with their partnership in respect to the Mountview Subdivision. ... These facts, when taken in connection with the other facts of the case, may be of the greatest importance, but when there are other facts to be considered this section will not be of much assistance. ... Rather it provides for the inter-provincial connection of the parties’ individual telecommunications signals, with a complicated method of revenue settlement, whereby certain revenues received from the operation of the system are attributed to each. ...
TCC
Northcor Energy Ltd. v. R., [1998] 1 CTC 3178, 97 DTC 1060
Many of the underlying transactions commence with persons who, in 1984, had no connection at all with the Appellant and its affiliated or ancestor corporations. ... Maximum Amount of CEE To Be Incurred The Partnership agrees to incur CEE pursuant to this Agreement up to a maximum amount of the net proceeds which are raised by the Partnership pursuant to any offering of its limited partnership units in connection with this Agreement. 10. ... Lalji was disciplined by the Institute of Chartered Accountants for the Province of Alberta in connection with some of his professional services rendered to Exco. ...
TCC
Erlich v. R., [1999] 2 CTC 2069, 99 DTC 572
The position advanced was that the similar facts were not logically relevant in determining the matter in issue in the present appeals nor was there any substantial connection between the actions of the Appellants during the period of time previously audited and the circumstances that are before the Court. [11] It is generally accepted that evidence of similar facts is considered collateral and is generally inadmissible unless there is, as Bull J.A. observed in MacDonald v. Canada Kelp Co.: [12]...a real and substantial nexus or connection between the act or allegation made, whether it be a crime or a fraud (but not, of course, limited to those), and facts relating to previous or subsequent transactions are sought to be given in evidence, then those facts have relevancy and are admissible not only to rebut a defence, such as lack of intent, accident, mens rea or the like, but to prove the fact of the act or allegations made.... Bull J.A. went on to say at page 627:...As I have indicated, the test is relevancy and relevancy depends largely on nexus or connection of the other transactions with the ones in issue- and a strong connection can well be admissible as relevant to the fact of the actus reus.... reus The question of the admissibility of similar fact evidence was also dealt with by McIntyre J. in R. v. ...
TCC
Kiwan c. La Reine, 2007 TCC 279, 2004 TCC 136
In this connection, she was allegedly sent in the spring of 1995 a document in Arabic that she had translated. ... I will discuss this issue later in connection with Ms. Langelier's findings during her testimony. [139] In 1993, Mr. ... In this connection, he cites the Quebec Court of Appeal decision in Légaré v. ...
TCC
Grenon v. The Queen, 2021 TCC 30
Reports were filed in connection with the First Distribution but no evidence was adduced to demonstrate that reports were filed in connection with the Second Distributions. d) The income distributions made by the Income Funds [48] The profits from the various investments or businesses were flowed-up through the various entities, including the FVT’s, to the Income Funds and were then distributed to unitholders, including the RRSP Trust. ... She acknowledged that a T3 return had not been filed with the CRA in connection with the RRSP Trust. ... However, I must conclude that she did so only in connection with the taxable plans and not in connection with the non-taxable plans that were listed for information purposes only, including the RRSP Trust. [534] As noted above, subsection 152(3) provides that “liability for tax” is not affected “by the fact that no assessment has been made.” ...
TCC
Birchcliff Energy Ltd. v. The Queen, 2017 TCC 234
Birchcliff approached several financial institutions including Scotia Capital in connection with financing the acquisition of the Devon Properties. 23. ... On April 18, 2005, Birchcliff notified the TSXV in connection with the proposed transactions. [45] 39. On April 18, 2005, Veracel notified shareholders of a special meeting in connection with proposed transactions. [46] 40. ...