Search - connection
Results 2061 - 2070 of 3270 for connection
TCC
JES Investments Ltd. v. The Queen, 2006 DTC 3608, 2006 TCC 508, aff'd 2007 FCA 337
The Corporation covenants and agrees with the Subscriber: (a) to keep proper books, records and accounts of all Qualifying Expenditures and all transactions affecting the Subscription Amount and the Qualifying Expenditures, and upon reasonable notice, to make such books, records and accounts available for inspection and audit by or on behalf of the Subscriber; (b) to incur, during the Expenditure Period, Qualifying Expenditures in such amount as enables the Corporation to renounce to the Subscriber in accordance with the Act and this Subscription Agreement, Qualifying Expenditures equal to the Subscription Amount with effect on or before December 31, 1997; (c) to renounce (in accordance with the Act and this Subscription Agreement) to the Subscriber, effective on or before December 31, 1997, Qualifying Expenditures incurred during the Expenditure Period equal to the Subscription Amount; (d) to make in a timely fashion all filings required in connection with this Subscription Agreement including, without limitation, the filings required by subsections 66(12.68) and 66(12.7) of the Act; (e) to mail to the subscriber, not later than March 31, 1998 a statement setting forth the aggregate amounts of Qualifying Expenditures renounced to the Subscriber pursuant hereto; (f) that all Qualifying Expenditures renounced to the Subscriber pursuant to this Subscription Agreement will be Qualifying Expenditures incurred by the Corporation that, but for the renunciation to the Subscriber, the Corporation would be entitled to deduct in computing its income for the purposes of Part I of the Act; (g) that the Corporation will not reduce the amount renounced to the Subscriber pursuant to subsection 66(12.6) of the Act or subsection 66(12.601) of the Act and, in the event the Minister reduces the amount renounced to the Subscriber pursuant to subsection 66(12.73) of the Act, the Corporation will indemnify the Subscriber for an amount not exceeding the amount of any increased tax payable under the Act, or the laws of a province, by the Subscriber as a consequence of such reduction; (h) that the Corporation will maintain its status as a "principal business corporation" (as defined in the Act) until at least January 1, 1999; (i) that the Corporation shall indemnify the Subscriber for an amount not exceeding the amount of any increased tax payable under the Act or the laws of Alberta by the Subscriber as a consequence of the failure of the Corporation to incur and renounce to the Subscriber Qualifying Expenditures equal to the Subscription Amount with effect on or before December 31, 1997; and (j) the Corporation shall, within ten days after the Closing Date, file a report with the Alberta Securities Commission in accordance with the provisions of subsection 108(1) of the Securities Act (Alberta). 10. ...
TCC
Freake v. The Queen, 2009 DTC 2071, 2009 TCC 568 (Informal Procedure)
The Queen, 2006 FCA 79, in similar factual situations, both this Court and the Federal Court of Appeal have found that the taxpayer is entitled to the deductions pursuant to paragraphs 8(1)(h) and (h.1), the latter paragraph in connection to motor vehicle expenses, and I am bound by the Appellate Court’s decision on this matter. ...
TCC
Walchuk v. The Queen, 2003 DTC 2184, 2004 TCC 42
Walchuk in connection with the business can support an intention to carry on the restaurant business with a view to profit equally with an intention to enhance the value of the business with a view to resell at a profit. ...
TCC
Barat v. M.N.R., 91 DTC 1097, [1991] 2 CTC 2360 (TCC)
Underground piping under the road and serving as a connection between the two properties did not make the properties contiguous. ...
TCC
Thomas v. The Queen, 2005 DTC 1527, 2005 TCC 613
., in respect of an eligible relocation of an individual in connection with which the individual begins employment at a new work location before October 1998; and (b) in any other case, after February 23, 1998. [19] An eligible housing loss is defined in subsection 6(22) as follows: (22) Eligible housing loss- In this section, "eligible housing loss" in respect of a residence designated by a taxpayer means a housing loss in respect of an eligible relocation of the taxpayer or a person who does not deal at arm's length with the taxpayer and, for these purposes, no more than one residence may be so designated in respect of an eligible relocation. [20] An eligible relocation is defined in subsection 248(1) of the Act as follows: "eligible relocation" means a relocation of a taxpayer where (a) the relocation occurs to enable the taxpayer (i) to carry on a business or to be employed at a location in Canada (in section 62 and this subsection referred to as "the new work location"), or... ...
TCC
Patricia & Daniel Blais O/A Satronics Satellites v The Queen, 2010 TCC 361, 2010 DTC 1271 [at 3904] (Informal Procedure)
The word "rental" is not a familiar one to use in connection with property rights of the kinds enumerated but I see no reason to think that when used in reference thereto it would connote characteristics different from those it has in its more familiar use in relation to tangible property. ...
TCC
Gilvesy v. The Queen, 96 DTC 1417, [1996] 3 CTC 2056 (TCC)
She also sent a direction to M.G.D. that the Deed and all documentation in connection with this sale be in the name of Vadnet or such other person as Vadnet may direct. ...
TCC
Humphrey v. The Queen, 2006 DTC 2730, 2006 TCC 168 (Informal Procedure)
Clayton Ruby in connection with Mr. Neeb's defence to the narcotics charge. ...
TCC
Schewe v. The Queen, 2010 DTC 1056 [at at 2810], 2010 TCC 47
[33] In Income Tax Bulletin IT-337R4 (consolidated) the words loss of employment or office are discussed and two questions are added to determine whether a connection exists for purposes of a retiring allowance which are as follows: 1 – But for the loss of employment would the amount have been received? ...
TCC
Aubrett Holdings Ltd. v. The Queen, [1998] GSTC 17 (TCC) (Informal Procedure)
The Respondent submits that subsection 141(5) deal with the ability to claim input tax credits when it is not clear that it’s a commercial activity because there may not be supplies. [42] The Respondent further submits that even if subsection 141(5) does apply it is helpful to their position because it deems activities undertaken in connection with a commercial activity, such as to start-up and wind-down the commercial activity, to be part of the commercial activity but it does not refer to exempt supplies which are excluded from the definition of a commercial activity. ...