Search - connection

Results 181 - 190 of 3279 for connection
TCC

Frank v. R., [1999] 1 CTC 2776

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^. [2] Dickson, J., agreed with Evans, J.A., in R. v. ...
TCC

Gingras v. R., [1998] 2 C.T.C. 2557

On December 2, 1988 the appellant made an application for such a pension. 5 The Canadian Pension Commission tribunal rendered a decision on March 14, 1990, retroactive to December 3, 1988, awarding the appellant a right to a pension under subsection 32(1) of the RCMPSA. 6 In accordance with paragraph 81(1)(i) of the Income Tax Act (the “Act”), the Minister did not include the pension received under that section in calculating the appellant's income. 7 In connection with the annuities received under paragraph 11(2)(b) of the RCMPSA, the appellant referred to paragraph 14 of Interpretation Bulletin IT-397R, which reads as follows: RCMP Pension or indemnity 14. ... Accordingly, it would appear that the taxpayer exercised his transfer rights in respect of this retirement allowance; however, I cannot say anything more in this connection as the point was not argued. 18 The appeals are dismissed. ...
TCC

Shih v. The Queen, 2000 DTC 2072 (TCC)

Apart from the presence of his wife and children in Regina, did the Appellant have other connections in Regina which would cause him to be resident there? ... The Appellant himself did not change his life pattern with respect to his continuous employment in Taiwan, continuing his professional connection with the Pharmaceutical Society, continuing his social connections at his church and tennis club, and finding a new dwelling in 1991 (Exhibit A-2) where he could eat, sleep, store clothes and take refuge. ... Regina may have been their family home but he was not there often enough or long enough to establish any personal connections with the various communities in Regina whether they be commercial, educational, cultural, recreational or social. ...
TCC

Gestion Forêt-Dale Inc. v. The Queen, 2009 DTC 1378, 2009 TCC 255

  [26]          Upon preparing the Appellant's income tax return, the accountants RTDD knew that the companies were not connected and that new shares would have to be issued in order to create the connection, hence the resolutions of 7:45 a.m. and 5:45 p.m. ... Meeting with Marco", it is acknowledged that the plan as it then existed did not contemplate a connection between the companies. ... I cannot believe that the accountants  at RTDD could have made the decision to create a connection between the companies on their own — a transaction which, in their view, was subject to the general anti‑avoidance rule —  without first obtaining Gaston Roy's consent or approval ...
TCC

Rock v. The Queen, 2010 TCC 607

She maintained that her connection to the reserves was fundamental to who she was. ... She dealt with high risk or at-risk aboriginal youth who lack a connection to their heritage. She referred to her job as a youth reunification officer working with urban youth to build their connection to the reserves running programs about native ceremonies, healing circles and history and building spiritual and cultural connections to help them out of their dysfunctional lifestyles ...
TCC

Gestion S.A.P. Inc. v. Minister of National Revenue, [1994] 1 CTC 2450, 94 DTC 1349

Indeed, on the facts before me it is clear that there is a connection between the farming and the food stores. ... In the case at bar, as I previously mentioned, there is a connection between the farming carried on by the appellant and its food stores. ... Petit Robert defines the word "connexion" as: The state of being connected; relation between connected things. ...
TCC

Arthur Clemiss v. Minister of National Revenue, [1987] 2 CTC 2275, 87 DTC 569

They import such meanings as “in relation to”, “with reference to" or “in connection with”. ... Savage were not in relation to or in connection with her employment. As Mr. ... In this connection he referred to the following passages from the decision of the Ontario Court of Appeal in Cooper v. ...
TCC

Owen Holdings Ltd. v. R., [1997] 3 C.T.C. 2286

They import such meanings as “in relation to”, “with reference to” or “in connection with”. ... These words convey a connection- the widest possible connection- between two related subject matters. In Rule 82 the connection is between the documents in a party's possession and matter in question between the parties. ...
TCC

Demetre Kiliaris v. Her Majesty the Queen; Zacharias Kiliaris v. Her Majesty the Queen; Gregoris Tricoris v. Her Majesty the Queen; Richard Taperek v. Her Majesty the Queen; Helen Moulas v. Her Majesty the Queen; Helen Kiliaris v. Her Majesty the Queen; And Isidoros Moulas v. Her Majesty the Queen, [1996] 3 CTC 2743, 97 DTC 7

However, he admitted in this connection that corporate documents were quite often not complete at the time of an audit. ... He said that he received nothing in this connection. In their testimony, both Mr. ... Although counsel for the parties gave me these articles after the hearing, they did not see fit to make any comment in this connection. ...
TCC

Carpenter v. The Queen, docket 97-281-GST-I (Informal Procedure)

The reason for the delay in making the application was that the Appellant had to travel frequently between in Simcoe Ontario and Vancouver in connection with the care of his daughter who is afflicted with multiple sclerosis. [3] The version of subsection 256(3) which imposes the deadline for filing the application for a rebate in the circumstances of this case reads: (3) A rebate shall not be paid under subsection (2) in respect of a residential complex to an individual unless the individual files an application for the rebate within two years after the earlier of (a) the day the complex is first occupied as described in subparagraph (2)(d)(i) or ownership is transferred as described in subparagraph (2)(d)(ii), and (b) the day construction or substantial renovation of the complex is substantially completed. ...

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