Search - connection

  (2) Evidence relating to taxpayer information − Notwithstanding any other Act of Parliament or other law, no official or other representative of a government entity shall be required, in connection with any legal proceedings, to give or produce evidence relating to any taxpayer information ... The prohibition of subsection (2) against disclosure of an income tax return "in connection with any legal proceeding" is subject to the exception of paragraph (3)(b) as to proceedings relating to the administration or enforcement of, among others, the Unemployment Insurance Act. ... The Order made here can still be made without a taxpayer knowing that his or her return is required to be disclosed in its entirety to a business connection. [27]   [20]          The judge also noted that the Minister did not appeal from the Order of the TCC. ...

On or about June 21, 2006, the appellant served a notice of objection on the Minister against the May 11, 2006, assessment, in connection with the 2005 taxation year.   7.         On or about June 14, 2007, the appellant served a notice of objection on the Minister against the June 7, 2007, assessment, in connection with the 2006 taxation year.   8.         ... Exhibit I‑4 is an appendix to the certificate with additional information supplied in connection with the "walking" activity. [5] In response to the question, [translation] "Is your patient able to walk (for example, 100 metres) using, as needed, any therapy . . . ...

There were, however, two provisos in connection with the outside work. ... The Royal Winnipeg Ballet covered expenses in connection with all travel, benefits, vacation pay and certain leaves. [58]     The more interesting position is that a one-season contract with The Royal Winnipeg Ballet is just one step along the professional dancer's career path, that might significantly impact on the future of that career. ... [61]     With respect to management of an independent business, there is little evidence of any such involvement, certainly in connection with the arrangement with The Royal Winnipeg Ballet. ...

Although RDI developed a methodology for testing in connection with the Y2K project, it had not created the actual rollover test or other standard methods in common use within the computer consulting industry. ... As for signing the contract- Exhibit A-4- Lamb stated the choice was either to work- or not- at the rate offered by RDI and he wanted the work, even if it meant agreeing to the status of an independent contractor in connection with the provision of his services. ... In addition, it entered into a contract with Phase Four to perform services in connection with a successful bid submitted by Phase Four in relation to the Y2K work. ...

When asked to comment on some of the weekly reports, she admitted that the employees' travel time in connection with work sites outside Montréal was paid for and that the payment could be made either in cash or by cheque. [50]          An important point, however, is that there was not the slightest thing in her testimony that could suggest that the information in the weekly reports does not reflect reality or that the reports may have subsequently been altered. [51]          As we know, the investigation by Mr. ... They also, he said, occasionally received a cheque to reimburse them for travel expenses in connection with work on sites outside Montréal. ... Furthermore, payment for travel time in connection with work sites outside Montréal was generally by cheque, as was the reimbursement of the travel and other expenses related to those sites. ...

Gastown appealed from this assessment. [2]            On October 7, 1998 the Minister assessed Gastown with respect to Canada Pension Plan contributions in the amount of $9,190.86 for the 1997 taxation year payable pursuant to the Canada Pension Plan in connection with the services performed by the individuals listed in Schedule A to the Reply to Notice of Appeal in respect of whose remuneration Gastown failed to make remittances to the Receiver General, as required. ... Dealing with the matter of integration, at p. 7- paragraph 13- I noted: "In terms of integration, it is clear the Club- a non-profit Society- was incorporated for purposes in connection with the sport of skating. ... The teaching of students privately, without any connection to the Club, occurred only after the requirements pursuant to the contract with the Club had been fulfilled. ...

In early 1986, the Appellant became concerned that it had significant financial exposure as a result of the commitments it and HOOL had made in connection with Bow Drill 3. ... From early 1986 until the end of September 1988, the Appellant engaged in concerted efforts to restrict its financial exposure in connection with Bow Drill 3. ... BVRS shall, or BVRS shall cause the relevant subsidiaries and affiliates including BVOD and BVODLP, to cooperate fully with the New Partnership in connection with the possible sale of the Rig to Maersk or its nominee including, without limitation, providing Maersk and its representatives with access to all necessary information and documentation respecting the Rig, excluding personnel and financial records, prior to the closing date, delivering such documentation and any other documentation in the possession of BVOD or BVODLP required by Schedule A to the Option Agreement to Maersk on the closing date, fully cooperating with Maersk in connection with the transfer of the ownership of the Rig and of the operational responsibilities for the Rig on or before the closing date including, without limitation, permitting Maersk to make use of BVOD's or BVODLP's operations and procedures manuals for the Rig for a period not to exceed 9 months after the closing date and permitting Maersk to make employment arrangements with BVODLP personnel. 4. ...

The Manager shall, during the term of this Agreement: a)         provide, or arrange for the provision of, portfolio advisory and investment management services with respect to the investment portfolio of each Class and make decisions as to the purchase and sale of portfolio securities, other dealings with the assets in the portfolio and execution of all portfolio transactions, including selection of market, dealer or broker and the negotiation, where applicable, of commissions, subject always to the direction of the Fund and the Board of Directors and the provisions of the Articles of Incorporation; b)         supervise any investment or portfolio advisors appointed in respect of the Classes; … d)         calculate, or cause to be calculated, as often as may be required by the Fund, the net asset value of the Fund, the net asset value of each Class and the series net asset value per share of each series offered by each Class; … f)         provide, or cause to be provided, services in respect of any or all of the Fund’s daily operations, including the processing of subscriptions for shares, the collection, and remission to the custodian of the Fund, of the moneys received by virtue of such subscriptions, the processing of requests for redemptions of shares and the processing of requests for the change of shares of any series if permitted under the eligibility criteria set out in the prospectus; … h)         provide, or cause to be provided, to the Fund all other administrative and other services and facilities required by the Fund in relation to its shareholders, including the preparation for and holding of meetings of shareholders of the Fund, of a Class or of a series of a Class, the maintenance of records regarding transactions of shareholders, registry and transfer agency services, services pertaining to distribution of income and gains to shareholders and other services for the provision of tax reporting and other information to shareholders; … l)          provide, or cause to be provided, to the Fund all other services necessary or desirable to conduct and operate the Fund’s business in an efficient manner. [52]         The Manager was able to delegate its responsibilities according to paragraph 4 of this Management Agreement as follows: In connection with the duties of the Manager herein specified, the Manager may, subject to the provisions of the Act and the Articles of Incorporation, engage or employ any persons as agents, representatives, employees or independent contractors, including, without limitation, lawyers, bankers, portfolio advisers, notaries, registrars, underwriters, accountants, brokers or dealers in one or more capacities and any other advisers or other professionals which the Manager deems advisable and may delegate any of the powers and duties of the Manager hereunder to any agents, representatives, officers, employee, independent contractors or other persons. ... The Funds may make arrangements to fund the payment of commissions to registered dealers in connection with the distribution of units of the Funds. ... Appendix   Subsection 123(1) – Division I – Interpretation – Definitions Definitions 123 (1) In section 121, this Part and Schedules V to X, … commercial activity of a person means (a) a business carried on by the person (other than a business carried on without a reasonable expectation of profit by an individual, a personal trust or a partnership, all of the members of which are individuals), except to the extent to which the business involves the making of exempt supplies by the person, (b) an adventure or concern of the person in the nature of trade (other than an adventure or concern engaged in without a reasonable expectation of profit by an individual, a personal trust or a partnership, all of the members of which are individuals), except to the extent to which the adventure or concern involves the making of exempt supplies by the person, and (c) the making of a supply (other than an exempt supply) by the person of real property of the person, including anything done by the person in the course of or in connection with the making of the supply; … debt security means a right to be paid money and includes a deposit of money, but does not include a lease, licence or similar arrangement for the use of, or the right to use, property other than a financial instrument;... exempt supply means a supply included in Schedule V; … financial instrument means (a) a debt security, (b) an equity security, (c) an insurance policy, (d) an interest in a partnership, a trust or the estate of a deceased individual, or any right in respect of such an interest, (e) a precious metal, (f) an option or a contract for the future supply of a commodity, where the option or contract is traded on a recognized commodity exchange, (g) a prescribed instrument, (h) a guarantee, an acceptance or an indemnity in respect of anything described in paragraph (a), (b), (d), (e) or (g), or (i) an option or a contract for the future supply of money or anything described in any of paragraphs (a) to (h); … financial service means (a) the exchange, payment, issue, receipt or transfer of money, whether effected by the exchange of currency, by crediting or debiting accounts or otherwise, (b) the operation or maintenance of a savings, chequing, deposit, loan, charge or other account, (c) the lending or borrowing of a financial instrument, (d) the issue, granting, allotment, acceptance, endorsement, renewal, processing, variation, transfer of ownership or repayment of a financial instrument, (e) the provision, variation, release or receipt of a guarantee, an acceptance or an indemnity in respect of a financial instrument, (f) the payment or receipt of money as dividends (other than patronage dividends), interest, principal, benefits or any similar payment or receipt of money in respect of a financial instrument, (f.1) the payment or receipt of an amount in full or partial satisfaction of a claim arising under an insurance policy, (g) the making of any advance, the granting of any credit or the lending of money, (h) the underwriting of a financial instrument, (i) any service provided pursuant to the terms and conditions of any agreement relating to payments of amounts for which a credit card voucher or charge card voucher has been issued, (j) the service of investigating and recommending the compensation in satisfaction of a claim where (i) the claim is made under a marine insurance policy, or (ii) the claim is made under an insurance policy that is not in the nature of accident and sickness or life insurance and (A) the service is supplied by an insurer or by a person who is licensed under the laws of a province to provide such a service, or (B) the service is supplied to an insurer or a group of insurers by a person who would be required to be so licensed but for the fact that the person is relieved from that requirement under the laws of a province, (j.1) the service of providing an insurer or a person who supplies a service referred to in paragraph (j) with an appraisal of the damage caused to property, or in the case of a loss of property, the value of the property, where the supplier of the appraisal inspects the property, or in the case of a loss of the property, the last-known place where the property was situated before the loss, (k) any supply deemed by subsection 150(1) or section 158 to be a supply of a financial service, (l) the agreeing to provide, or the arranging for, a service that is (i) referred to in any of paragraphs (a) to (i), and (ii) not referred to in any of paragraphs (n) to (t), or (m) a prescribed service, but does not include (n) the payment or receipt of money as consideration for the supply of property other than a financial instrument or of a service other than a financial service, (o) the payment or receipt of money in settlement of a claim (other than a claim under an insurance policy) under a warranty, guarantee or similar arrangement in respect of property other than a financial instrument or a service other than a financial service, (p) the service of providing advice, other than a service included in this definition because of paragraph (j) or (j.1), (q) the provision, to an investment plan (as defined in subsection 149(5)) or any corporation, partnership or trust whose principal activity is the investing of funds, of (i) a management or administrative service, or (ii) any other service (other than a prescribed service), if the supplier is a person who provides management or administrative services to the investment plan, corporation, partnership or trust, (q.1) an asset management service, (r) a professional service provided by an accountant, actuary, lawyer or notary in the course of a professional practice, (r.1) the arranging for the transfer of ownership of shares of a cooperative housing corporation, (r.2) a debt collection service, rendered under an agreement between a person agreeing to provide, or arranging for, the service and a particular person other than the debtor, in respect of all or part of a debt, including a service of attempting to collect, arranging for the collection of, negotiating the payment of, or realizing or attempting to realize on any security given for, the debt, but does not include a service that consists solely of accepting from a person (other than the particular person) a payment of all or part of an account unless (i) under the terms of the agreement the person rendering the service may attempt to collect all or part of the account or may realize or attempt to realize on any security given for the account, or (ii) the principal business of the person rendering the service is the collection of debt, (r.3) a service (other than a prescribed service) of managing credit that is in respect of credit cards, charge cards, credit accounts, charge accounts, loan accounts or accounts in respect of any advance and is provided to a person granting, or potentially granting, credit in respect of those cards or accounts, including a service provided to the person of (i) checking, evaluating or authorizing credit, (ii) making decisions on behalf of the person in relation to a grant, or an application for a grant, of credit, (iii) creating or maintaining records for the person in relation to a grant, or an application for a grant, of credit or in relation to the cards or accounts, or (iv) monitoring another person’s payment record or dealing with payments made, or to be made, by the other person, (r.4) a service (other than a prescribed service) that is preparatory to the provision or the potential provision of a service referred to in any of paragraphs (a) to (i) and (l), or that is provided in conjunction with a service referred to in any of those paragraphs, and that is (i) a service of collecting, collating or providing information, or (ii) a market research, product design, document preparation, document processing, customer assistance, promotional or advertising service or a similar service, (r.5) property (other than a financial instrument or prescribed property) that is delivered or made available to a person in conjunction with the rendering by the person of a service referred to in any of paragraphs (a) to (i) and (l), (s) any service the supply of which is deemed under this Part to be a taxable supply, or (t) a prescribed service; … management or administrative service includes an asset management service; … money includes any currency, cheque, promissory note, letter of credit, draft, traveller’s cheque, bill of exchange, postal note, money order, postal remittance and other similar instrument, whether Canadian or foreign, but does not include currency the fair market value of which exceeds its stated value as legal tender in the country of issuance or currency that is supplied or held for its numismatic value; … property means any property, whether real or personal, movable or immovable, tangible or intangible, corporeal or incorporeal, and includes a right or interest of any kind, a share and a chose in action, but does not include money; … service means anything other than (a) property, (b) money, and (c) anything that is supplied to an employer by a person who is or agrees to become an employee of the employer in the course of or in relation to the office or employment of that person; … supply means, subject to sections 133 and 134, the provision of property or a service in any manner, including sale, transfer, barter, exchange, licence, rental, lease, gift or disposition; … taxable supply means a supply that is made in the course of a commercial activity; Section 217 – Division IV – Tax on Imported Taxable Supplies – Definitions Definitions 217 The following definitions apply in this Division. … imported taxable supply means (a) a taxable supply (other than a zero-rated or prescribed supply) of a service made outside Canada to a person who is resident in Canada, other than a supply of a service that is (i) acquired for consumption, use or supply exclusively in the course of commercial activities of the person or activities that are engaged in exclusively outside Canada by the person and that are not part of a business or an adventure or concern in the nature of trade engaged in by the person in Canada, (ii) consumed by an individual exclusively outside Canada (other than a training service the supply of which is made to a person who is not a consumer), (iii) in respect of real property situated outside Canada, (iv) a service (other than a custodial or nominee service in respect of securities or precious metals of the person) in respect of tangible personal property that is (A) situated outside Canada at the time the service is performed, or (B) exported as soon after the service is performed as is reasonable having regard to the circumstances surrounding the exportation and is not consumed, used or supplied in Canada after the service is performed and before the exportation of the property, (v) a transportation service, or (vi) a service rendered in connection with criminal, civil or administrative litigation outside Canada, other than a service rendered before the commencement of such litigation, (b) a taxable supply (other than a zero-rated or prescribed supply) of tangible personal property made by a non-resident person who is not registered under Subdivision d of Division V to a recipient who is a registrant where (i) physical possession of the property is transferred to the recipient in Canada by another registrant who (A) made a supply in Canada of the property by way of sale, or a supply in Canada of a service of manufacturing or producing the property, to a non-resident person, or (B) acquired physical possession of the property for the purpose of making a supply of a commercial service in respect of the property to a non-resident person, (ii) the recipient gives the other registrant a certificate of the recipient described in paragraph 179(2)(c), and (iii) the recipient is not acquiring the property for consumption, use or supply exclusively in the course of commercial activities of the recipient or the property is a passenger vehicle that the recipient is acquiring for use in Canada as capital property in commercial activities of the recipient and that has a capital cost to the recipient exceeding the amount deemed under paragraph 13(7)(g) or (h) of the Income Tax Act to be the capital cost of the vehicle to the recipient for the purposes of section 13 of that Act, (b.1) a taxable supply (other than a zero-rated or prescribed supply) of tangible personal property made at a particular time by a non-resident person who is not registered under Subdivision d of Division V to a particular recipient who is resident in Canada, where (i) the property is delivered or made available in Canada to the particular recipient and the particular recipient is not a registrant who is acquiring the property exclusively for consumption, use or supply in the course of commercial activities of the recipient, and (ii) the non-resident person previously made a taxable supply of the property by way of lease, licence or similar arrangement to a registrant who was not dealing at arm’s length with the non-resident person or who was related to the particular recipient, the property was delivered or made available in Canada to the registrant, the registrant was entitled to claim an input tax credit in respect of the property or was not required to pay tax under this Division in respect of the supply only because the registrant acquired the property exclusively for consumption, use or supply in the course of commercial activities of the registrant, and that supply was the last supply of the property made before the particular time by the non-resident person to a registrant, (b.11) a particular taxable supply (other than a zero-rated supply) of property by way of lease, licence or similar arrangement that is deemed under subsection 143(1) to be made outside Canada to a recipient (in this paragraph referred to as the “lessee”) who is resident in Canada, if (i) a previous supply of the property to the lessee was made by way of lease, licence or similar arrangement (in this paragraph referred to as the “first lease”) that was deemed under subsection 178.8(4) to be made in Canada, (ii) the agreement for the particular taxable supply is an agreement (in this subparagraph referred to as a “subsequent lease”) that results from the assignment of, or that succeeds, upon the renewal or variation of, the first lease or a subsequent lease, and (iii) the lessee is not a registrant who is acquiring the property for consumption, use or supply exclusively in the course of commercial activities of the lessee; (b.2) a taxable supply of a continuous transmission commodity, if the supply is deemed under section 143 to be made outside Canada to a registrant by a person who was the recipient of a supply of the commodity that was a zero-rated supply included in section 15.1 of Part V of Schedule VI or that would, but for subparagraph (a)(v) of that section, have been included in that section, and the registrant is not acquiring the commodity for consumption, use or supply exclusively in the course of commercial activities of the registrant, (b.3) a supply, included in section 15.2 of Part V of Schedule VI, of a continuous transmission commodity that is neither exported, as described in paragraph (a) of that section, nor supplied, as described in paragraph (b) of that section, by the recipient and the recipient is not acquiring the commodity for consumption, use or supply exclusively in the course of commercial activities of the recipient, (c) a taxable supply (other than a zero-rated or prescribed supply) of intangible personal property made outside Canada to a person who is resident in Canada, other than a supply of property that (i) is acquired for consumption, use or supply exclusively in the course of commercial activities of the person or activities that are engaged in exclusively outside Canada by the person and that are not part of a business or an adventure or concern in the nature of trade engaged in by the person in Canada, (ii) may not be used in Canada, or (iii) relates to real property situated outside Canada, to a service to be performed wholly outside Canada or to tangible personal property situated outside Canada, (c.1) a taxable supply made in Canada of intangible personal property that is a zero-rated supply only because it is included in section 10 or 10.1 of Part V of Schedule VI, other than (i) a supply that is made to a consumer of the property, or (ii) a supply of intangible personal property that is acquired for consumption, use or supply exclusively in the course of commercial activities of the recipient of the supply or activities that are engaged in exclusively outside Canada by the recipient of the supply and that are not part of a business or adventure or concern in the nature of trade engaged in by that recipient in Canada, (d) a supply of property that is a zero-rated supply only because it is included in section 1.1 of Part V of Schedule VI, if the recipient is not acquiring the property for consumption, use or supply exclusively in the course of commercial activities of the recipient and (i) an authorization of the recipient to use the certificate referred to in that section is not in effect at the time the supply is made, or (ii) the recipient does not export the property in the circumstances described in paragraphs 1(b) to (d) of that Part; or (e) a supply of property that is a zero-rated supply only because it is included in section 1.2 of Part V of Schedule VI, if the recipient is not acquiring the property for consumption, use or supply exclusively in the course of commercial activities of the recipient and (i) an authorization of the recipient to use the certificate referred to in that section is not in effect at the time the supply is made, or (ii) the recipient is not acquiring the property for use or supply as domestic inventory or as added property (as those expressions are defined in subsection 273.1(1)).   ...

Specifically, these are as follows: Date Payee Rounded Amount August 2008   Cruise Connections   $81,159 December 2008   Cruise Connections   $112,210 February 2009     DBS Capital Management $27,027 March 2009   DBS Capital Management $5,000 Multiple Dates   Kimberly Booth-consulting $27,225 Multiple Dates   May Concepcion   $15,000     Total_____________ $267,622   Analysis and Decision [64]   The following disallowed bonuses (aside from the EPSP amounts) remained in dispute:   Payee   Amount Joanell Skykora   $20,314 Maria Cunha   $22,442 Maria Cunha (tax remittances)   $6,003 Vanessa Cunha   $800 A.   ... Finally, such a payout method was common during the 2007 to 2008 period; it was undertaken in order to reduce corporate income to the small business limit by paying bonuses and salaries to the extent of such an amount. [83]   The Respondent’s submissions take issue with the Appellants’ characterization of the smallest connection or nexus to employment argument. ... Bonuses   $519,472.00     Cruise connection, DBS, MC  -$267,620.99 $251,851.01         IV.   ...

These definitions do not help us a great deal in clarifying the scope of the notion of series, apart from the last one, which acknowledges the existence of a certain connection among the various transactions. A literal application of these definitions of the word series could lead us to adopt a very broad definition so that numerous events following one another and having a certain connection among them could be part of a series of transactions or events. ... There was therefore a closer connection here between the right of first refusal granted on April 7, 1980, and the sale of September 15, 1980. ...