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Results 1261 - 1270 of 3270 for connection
TCC

Galaxy Management Ltd. v. The Queen, 2005 DTC 1558, 2005 TCC 674

Both appear to have been cobbled together using inappropriate precedents. [18]     The agency agreement between Galaxy and Fountain Set contains the following terms among others: 1.1        The Principal hereby engages and appoints the Agent as an agent on the sales of their fabric products in Western Canada. 1.2        The Agent accepts such appointment and agrees to keep and perform all the duties and obligations under the terms and conditions of this Agreement. 2.1        The term of the employment shall commence from the 1st day of September 1998 and continue unless terminated earlier by either party. 3.0        Services 3.1        The Employee shall: (a)         devote sufficient time, attention, skills and efforts in connection with the Principal's business, and comply with all instructions, directions, request, rules and regulations made and issued by the Principal; (b)         perform services conscientiously and to the full limit of his ability at all times and whenever and wherever required and desired by the Principal; (c)         carry out faithfully such duties and exercise such powers form time to time as the Principal may prescribe; 4.0        Compensation 4.1        Providing the Agent fulfills his obligations under this Agreement, and as full consideration for all services rendered or to be rendered to the Principal, the Principal shall pay the Agent a commission of 1.5% on the sales of the fabric products contributed to the Principal and the Principal will release the compensation to the Agent on a monthly basis. 4.2        The Agent agrees that the Principal may deduct and withhold from the compensation payable to the Agent under the provisions of any statute, regulation or order and any and all amendments thereto requiring the withholding or deduction of compensation. 4.3        The Agent shall be responsible for all expenses in connection with the services rendered under this Agreement. 4.4.       ...
TCC

Giguere v. The Queen, 2005 DTC 646, 2005 TCC 257

Accordingly, the Southwind factors are useful in analyzing whether there exists, on the facts of this particular case, a connection between the Appellants' admittedly off-reserve business activities and the Thessalon Reserve so as to render their business income exempt from taxation under section 87. (1)      the location of the business activities; [17]     Since 1992, the business address of Clara Giguere Trucking and William Giguere Trucking David Giguere has been the Thessalon Reserve. ... This is not particularly significant as even if the Appellants had lived on the Thessalon Reserve for the entire period, that in itself would not outweigh the other factors pointing to a lack of connection between the businesses and the reserve. [26]     To summarize, the business activities of William Giguere and Clara Giguere were such that they could only be accomplished off-reserve, almost completely in a context not "integrated into reserve life" as described in Recalma: their customer, Meakin Forest, was located off the reserve. ...
TCC

Morisset c. La Reine, 2008 DTC 3864, 2006 TCC 483

A chiropractor performs and prescribes tests, examinations and analyses of the patient's state of health to assess the appropriateness and efficacy of the chiropractor’s treatment or in connection with the chiropractor’s illness prevention program. ... A chiropractor advises professionals concerned with the workplace, or with the prevention of accidents on duty or work-related illnesses, or the prevention of traffic accidents, and performs assessments in connection with these matters.  ...   12. ...
TCC

Bernier v. The Queen, 2004 DTC 3235, 2004 TCC 376

In 1998, he paid $29,755.33 in interest in connection with a line of credit, and he claimed an equivalent deduction in calculating his business income.  The Minister of National Revenue disallowed the deduction, because the interest had not been paid in connection with a loan used for the purpose of earning income from a business or property.  ...
TCC

Donato v. The Queen, 2009 DTC 1384 [at at 2111], 2009 TCC 590

Through that connection, he decided to make a charitable donation of a large portion of his cartoon collection to that institution. ... ”   [50]     Based on the evidence, the tangible works of art were used in connection with the Sun Media contract, and this was the primary use of this property. ...
TCC

Clarke v. MNR, 92 DTC 2267, [1992] 2 CTC 2743 (TCC)

The appellant also lives on the reserve which buttresses the connection to the reserve through his employment. ... By definition it may be that there was a cultural connection between the services of the employer and the residents of the reserve, however, there is no specific evidence to support this position. ...
TCC

Suzanne Sterling-Ross v. The Queen, 2009 DTC 1892, 2009 TCC 525 (Informal Procedure)

Factual background   [27]     The background to this matter was provided in testimony from two officials of the Canada Revenue Agency: Scott Arner, who performed the GST audit, and John Possmayer, who subsequently performed an investigation that led to criminal charges being laid against the appellants in connection with the ITC claims ...   [33]     At the criminal hearing, it was acknowledged that civil proceedings were underway in connection with the assessments as well ...
TCC

Pappas Estate v. MNR, 90 DTC 1646, [1990] 2 CTC 2132 (TCC)

Another instance of executor time being spent on the question of the extent of the entitlement of each beneficiary arose in connection with the U.S. bank accounts. ... Finally, I turn to the deductibility of costs incurred in connection with the investment of liquid assets. ...
TCC

Gernhart v. The Queen, 96 DTC 1672, [1996] 3 CTC 2369 (TCC), briefly aff'd 98 DTC 6026 (FCA), Docket: A-625-96

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

Cammidge v. The Queen, 2011 DTC 1146 [at at 782], 2011 TCC 172 (Informal Procedure)

Counsel for the Minister argued that the courses the Appellant took had no connection to the Canadian campuses, which she did not attend, and therefore the tuition fees paid for those courses is not deductible under paragraph 118.5(1)(a) of the Act ... Subsection 118.6(1) states, in part:   118.6(1) Definitions    For the purposes of sections 63 and 64 and this subdivision,   “designated educational institution” – “designated educational institution” means               (a) an educational institution in Canada that is               (i) a university, college or other educational institution designated by the Lieutenant Governor in Council of a province as a specified educational institution under the Canada Student Loans Act, designated by an appropriate authority under the Canada Student Financial Assistance Act, or designated by the Minister of Higher Education and Science of the Province of Quebec …, or               (ii) certified by the Minister of Human Resources and Skills Development to be an educational institution providing courses, other than courses designed for university credit, that furnish a person with skills for, or improve a person’s skills in, an occupation,               (b) a university outside Canada at which the individual referred to in subsection (2) was enrolled in a course, of not less than 13 consecutive weeks duration, leading to a degree, or   …   [18]          The Act provides an expansive definition of “ Canada ” in section 255, which states:   SECTION 255:   Canada               For the purposes of this Act, “ Canada ” is hereby declared to include and to have always included               (a) the sea bed and subsoil of the submarine areas adjacent to the coasts of Canada in respect of which the Government of Canada or of a province grants a right, licence or privilege to explore for, drill for or take any minerals, petroleum, natural gas or any related hydrocarbons; and               (b) the seas and airspace above the submarine areas referred to in paragraph (a) in respect of any activities carried on in connection with the exploration for or exploitation of the minerals, petroleum, natural gas or hydrocarbons referred to in that paragraph ...

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