Search - connection
Results 1251 - 1260 of 3270 for connection
TCC
Taylor v. The Queen, 2010 DTC 1189 [at at 3449], 2010 TCC 246
Taylor’s residence in connection with suspected offences under the Income Tax Act ... Gerard Tompkins, was retained a few months later in connection with the objection process ...
TCC
Coughlan v. The Queen, 2001 DTC 719 (TCC)
Seabright had placed insurance to protect the directors from liability for wrongful acts and defaults alleged against them in connection with their duties as directors. ... I accept the Appellant's evidence that these two amounts, although given as damages for breach of the indemnity and for the loss of insurance benefits, did not fully compensate him for the amounts he spent in connection with the litigation in Ontario and Nova Scotia. [9] Between the years 1989 and 1994, the Appellant spent some $4,725,635 in defence of the Ontario actions and in prosecuting the Nova Scotia actions, and he claimed to be entitled to deduct these amounts in computing his income. ...
TCC
Williams v. The Queen, 2004 DTC 3549, 2004 TCC 706
(f) where the taxpayer was employed in the year in connection with the selling of property or negotiating of contracts for the taxpayer's employer, and (i) under the contract of employment was required to pay the taxpayer's own expenses, (ii) was ordinarily required to carry on the duties of the employment away from the employer's place of business, (iii) was remunerated in whole or part by commissions or other similar amounts fixed by reference to the volume of the sales made or the contracts negotiated, and (iv) was not in receipt of an allowance for travel expenses in respect of the taxation year that was, by virtue of subparagraph 6(1) (b) (v), not included in computing the taxpayer's income, amounts expended by the taxpayer in the year for the purpose of earning the income from the employment (not exceeding the commissions or other similar amounts referred to in subparagraph (iii) and received by the taxpayer in the year) to the extent that those amounts were not (v) outlays, losses or replacements of capital or payments on account of capital, except as described in paragraph (j), (vi) outlays or expenses that would, by virtue of paragraph 18(1) (l), not be deductible in computing the taxpayer's income for the year if the employment were a business carried on by the taxpayer, or (vii) amounts the payment of which reduced the amount that would otherwise be included in computing the taxpayer's income for the year because of paragraph 6(1) (e); ... ... M.N.R. [4] where he indicated: Dealing firstly with section 8(1) (f) (i), (and I will paraphrase), certain expenses are deductible (by the taxpayer) where they are incurred in connection with the selling of property for his employer and where under the contract of employment the employee was required to pay his own expenses. ...
TCC
MacMillan Bloedel Ltd. v. R., 97 DTC 1446, [1997] 3 C.T.C. 3012 (TCC), aff'd 99 DTC 5154
All of which is without costs. 2 Accordingly, in connection with those issues set out in the Consent to Judgment, judgment will issue in accordance with the Consent to Judgment filed. 3 The remaining issue deals with a capital loss under subsection 39(2) of the Income Tax Act (the “ Act ”) claimed by the Appellant in its 1987 taxation year. ... In that case, the fluctuations came about in connection with borrowing and repaying. ...
TCC
Louis-Phillipe Bédard v. Minister of National Revenue, 91 DTC 573, [1991] 1 CTC 2323 (TCC)
The relevant passage from that decision is the following (at 2264 (D.T.C. 558)): “The phrase ‘in respect of’ is probably the widest of any expression intended to convey some connection between two related subject matters.” ... Horwitz in his argument had neither acknowledged nor denied that there was any direct connection, chronological or otherwise, between the “ dismissal”, and the "exemplary damages" or the amount for "mental distress". ...
TCC
Donovan v. The Queen, 94 DTC 1143, [1994] 1 CTC 2394 (TCC), aff'd 96 DTC 6085 (FCA)
I come to the conclusion that the value of the benefit is substantial for several different reasons, namely: Firstly There is no connection between the large non-interest bearing loans to Holdings in the years 1986, 1987 and 1988 to the original cost of the house. ... The appellant cannot demonstrate a connection between the original cost of these assets and his shareholder loans in 1986, 1987 and 1988. ...
TCC
Bakorp Management Ltd. v. The Queen, 2015 TCC 36, aff'd supra.
The Appellant was assessed Part IV taxes in connection with dividends received for its 1993 and 1995 taxation years, initially as filed. ... Moreover, the Appellant’s T2 income tax return entered into evidence shows the payment made on account of 1995 and the parties agree it was paid on June 10, 1995. [18] Accordingly, based on a textual, contextual and purposive approach, it would be inconsistent and unharmonious to interpret subsection 187(2) to mean that any payment made in connection with a particular year can apply to any other year, as the Appellant alleges. ...
TCC
Roy Legumex Inc. v. MNR, 90 DTC 1858, [1990] 2 CTC 2389 (TCC)
The word "attached" in subparagraph (b)(ii) contemplates more than a simple connection. ... The phrase "faisant partie" confirms that the word "attached" in the English language version of subparagraph (b)(ii) means more than a mere connection; the tangible property must be so attached to the building that it more or less becomes part of it. ...
TCC
Stone Container (Canada) Inc. v. R., 98 DTC 1508, [1998] 3 CTC 2150 (TCC)
They import such meanings as “in relation to”, “with reference to” or “in connection with”. The phrase “in respect of” is probably the widest of any expression intended to convey some connection between two related subject matters. ...
TCC
830480 Alberta Inc. v. The Queen, 2013 DTC 1027 [at at 132], 2012 TCC 424
That question does not arise only in connection with strict liability offences, although with the growth in regulations and the multiplication of statutory offences the field of strict liability has proven to be the most fertile for the emergence of this defence. ... ] [26] I agree with counsel’s submission that a taxpayer can avoid late filing penalties if the taxpayer can show, on a balance of probabilities, that he or she had reasonable grounds to believe that no taxes were owed in connection with the returns that were filed late. ...