Search - connection

I do not find that high degree of negligence in connection with the misstatements of business income. ...

I do not find that high degree of negligence in connection with the misstatements of business income. ...

I do not find that high degree of negligence in connection with the misstatements of business income. ...

However, he could not turn his personal choice to his advantage and, above all, rely on that choice to consider himself a worker who was obliged to travel long distances to perform his duties. [53]     The evidence shows that there were no reasonable or valid grounds to explain or support the appellant's choice to keep a residence in Notre-Dame-Des-Bois so as to be able to establish that his residence in Québec was required for the performance of his duties. [54]     The amounts received by the appellant were basically income received in connection with his employment; the appeals must therefore be dismissed. ...

I do not find that high degree of negligence in connection with the misstatements of business income. ...

How did they deal with the HST on their legal costs in connection with a short-lived business many years prior to incurring those costs? ...

The provision reads as follows: 8(1)(f)        where the taxpayer was employed in the year in connection with the selling of property or negotiating of contracts for the taxpayer’s employer, and   (i) under the contract of employment was required to pay the taxpayer’s own expenses, (ii) was ordinarily required to carry on the duties of the employment away from the employer’s place of business, (iii) was remunerated in whole or part by commissions or other similar amounts fixed by reference to the volume of the sales made or the contracts negotiated, and (iv) was not in receipt of an allowance for travel expenses in respect of the taxation year that was, by virtue of subparagraph 6(1)(b)(v), not included in computing the taxpayer’s income, amounts expended by the taxpayer in the year for the purpose of earning the income from the employment (not exceeding the commissions or other similar amounts referred to in subparagraph 8(1)(f)(iii) and received by the taxpayer in the year) to the extent that those amounts were not (v) outlays, losses or replacements of capital or payments on account of capital, except as described in paragraph 8(1)(j), (vi) outlays or expenses that would, by virtue of paragraph 18(1)(l), not be deductible in computing the taxpayer’s income for the year if the employment were a business carried on by the taxpayer, or (vii) amounts the payment of which reduced the amount that would otherwise be included in computing the taxpayer’s income for the year because of paragraph 6(1)(e); ...

  [9]               Commercial activity is defined in subsection 123(1) of the Act as follows:   “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.     ...

  [56]          In connection with the Worker’s decision to withdraw her Notice of Intervention, Counsel for the Respondent said:   MS. ...

While I find its conduct above should further deny its claim for solicitor and client costs, I do not find that on the whole, seen in conjunction with the Respondent’s conduct in ignoring its own rules, that the Appellant should be denied less than full party and party costs in accordance with the Tariff, save and except that it shall be entitled to no more than the $1,000 awarded by Rip C.J. in connection with costs on the Settlement Conference and save further that, having regard to the limited value of its expert witness report, it should only be given an award for expert witness fees based on 77.99% of the whole fees ...