Search - connection

Results 1471 - 1480 of 3270 for connection
TCC

Reiss Estate v. The Queen, docket 94-3199-IT-G

All costs with respect to connections to the municipal sewer system would have to be borne by the developer or the land owner. ... In this connection, he noted that there was a difference in zoning as regards the subject property. ... In this connection, Mr. Weatherby envisioned a layout of a development for the subject property. ...
TCC

Joncas v. The Queen, docket 98-1096-IT-G

Lair stated that the appellant had told the committee members at that meeting that he had sold Trans Côte retroactive to January 1, 1992 and, in connection with that sale, a notary had been appointed trustee. ... Côté to sell everything that had me involved in air transport, that had a connection with air transport and the Centre de santé. ... In connection with those transactions, Mr. Labadie filed a document that he said was prepared according to his instructions in 1997. ...
TCC

Contractor v. The Queen, 2021 TCC 46

I can identify no connection whatsoever between the information requested regarding Mr. ... However, it is clear from the questions preceding question 2052 that counsel for the Respondent did have a copy and had presented that copy to YC. [68] The response states that YC is unable to locate the letter. [79] I can identify no connection between the request for production of the CRA deficiency letter and any of the matters in issue in the appeals. ... However, the Respondent has not identified a connection between the delay in bringing a motion to address YC undertaking numbers 13 to 28 and the pandemic. ...
TCC

River Cree Resort Limited Partnership v. The Queen, 2022 TCC 45

(i) Connection to the Network [53] Access connected the ATMs to TNS’s network. ... If the Appellant had retained Access to provide connection services, I would have expected the Appellant to pay for those services. ... The Appellant supplied the location, the electricity and the internet connection. ...
TCC

Reiss Estate v. R., 98 D.T.C. 1455, [1998] 2 C.T.C. 3136

All costs with respect to connections to the municipal sewer system would have to be borne by the developer or the land owner. ... In this connection, he noted that there was a difference in zoning as regards the subject property. ... In this connection, Mr. Weatherby envisioned a layout of a development for the subject property. ...
TCC

Foreman v. MNR, 93 DTC 7, [1992] 2 CTC 2621 (TCC)

The substance of subparagraph 5(a) does not appear in the replies to notice of appeal filed in connection with the appeals of appellants Foreman and Wilson. ... While it is true that these decisions dealing with the concept of disposition involve the application of provisions of the Income Tax Act dealing with the subject matter of capital cost allowances, I am satisfied that some of the general observations made in these cases about the import of the words "dispose of” may be of some assistance in connection with the present appeals. ...
TCC

Klemen v. The Queen, 2014 DTC 1170 [at at 3613], 2014 TCC 244

Work expended on or in connection with the property realized. [If the taxpayer completes steps to improve the property for resale, it is more likely inventory.] 5.     ... Section 123 of ETA defines a “commercial activity”  as: (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. ...
TCC

Lau v. The Queen, [2007] GSTC 171, 2007 TCC 718

No party shall by reason of any provision herein contained be deemed to be the partner, agent or legal representative of any other party or parties, whether for the purposes of this Agreement, the Project or otherwise, nor shall any party have, nor represent itself to have, any authority or power to act for, or to undertake any obligation or responsibilities on behalf of, any other party or parties, for the Project or otherwise, except as may herein be expressly provided.   2.5       The obligations of the Joint Venturers with respect to the Project and all contracts and obligations entered into by the Joint Venturers in connection therewith shall, in every case, be several to the extent of each party’s Proportionate Interest, and not joint or joint and several, unless expressly otherwise agreed to in writing by both of the Joint Venturers.   2.6       Neither the trustee of Golden Leaf nor any officer or employee of such trustee shall be held personal liability under this agreement or otherwise in respect of the Project or the Joint Venture except to the extent that such liability can be enforced against or satisfied out of Golden Leaf’s Proportionate Interest Only.   8.3       All interest, profit and advantage arising or accruing from the Lands and all costs incurred or accrued in connection therewith shall be received, held or incurred by the Trustee [GL Trust] for the use, benefit and advantage or cost of the Joint Venturers in the respective proportions referred to in Section 8.2 above.  ...
TCC

Sokolowski Romar v. The Queen, 2013 DTC 1003 [at at 24], 2012 TCC 104

They then proceeded to audit his 1985 tax return and on July 17, 1987, he received a letter from Revenue Canada informing him that, following the audit, Revenue Canada planned to adjust his 1985 tax return, rejecting the losses of approximately $3 million he had claimed in connection with a partnership and other expenses and giving him 30 days to make representations before it issued a new notice of assessment. ... Livingston, 2008 DTC 6233, Justice Sexton of the Federal Court of Appeal laid down the criteria of application of section 160 in connection with the purpose and spirit of subsection 160(1):   [9] The   Tax Court Judge   determined that in order for subsection 160(1) of the Act to apply, the following four criteria must be met:   1)             There must be a transfer of property;   2)      The parties must not be dealing at arm's length;   3)      There must be no consideration or inadequate consideration flowing from the transferee to the transferor (I would note that the trial judge considered the test to be “No consideration or inadequate consideration flowing from the   transferor   to the   transferee ” [emphasis added]: this is a mistaken quotation of the test as cited in   Raphael v. ...
TCC

Leduc v. The Queen, 2005 DTC 250, 2005 TCC 96

Consequently, it is the activity that resulted in the charges and its connection to the business that determine the deductibility of the legal expenses associated with the defence. [27]     Furthermore, counsel for the appellant relied on another decision of the Supreme Court of Canada, 65302 British Columbia Ltd. v. ... In the case of a member, an order that the member not maintain any trust account in connection with his or her practice without leave of the chair or a vice-chair of the standing committee of Convocation responsible for discipline matters. 13. ...

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