Search - connection

Either the services are rendered in the "discharge of functions of a governmental nature" or they are rendered in "connection with a trade or business". ... However, if the services are rendered in connection with a trade or business, then the provisions of Article XIV (Independent Personal Services), Article XV (Dependent Personal Services), or Article XVI (Artistes and Athletes), as the case may be, are controlling. ... The context for the purpose of the interpretation of a treaty shall comprise, in addition to the text, including the preamble and annexes: (a) any agreement relating to the treaty which was made between all the parties in connection with the conclusion of the treaty; (b) any instrument which was made by one or more parties in connection with the conclusion of the treaty and accepted by the other parties as an instrument related to the treaty; 3.      ...

., raises three issues in its appeal of the Minister of National Revenue (the Minister) assessment of its goods and services tax (GST) liability: (i)       the denial by the Minister of input tax credits (ITCs) of $743.40 in connection with the construction of a bison fence; (ii)       the denial by the Minister of the ITCs of $392.59 in connection with work provided by RC Electro Comp; and (iii)      the imposition of penalties pursuant to section 280 of the Excise Tax Act (the Act). [2]      The Appellant was owned entirely by Mr. ... Woloszyn the full amount of $11,363.40. [3]      The invoice from RC Electro Comp in the amount of $6,001.03, including $392.59 of GST, was primarily for materials in connection with a gravel crusher. ... Analysis Bison Fence ITC [5]      The first issue is the Appellant's entitlement to an ITC in connection with the bison fence. ...

(v)         reasonable allowances for travel expenses received by an employee from the employee's employer in respect of a period when the employee was employed in connection with the selling of property or negotiating of contracts for the employee's employer,            ... (vii)       reasonable allowances for travel expenses (other than allowances for the use of a motor vehicle) received by an employee (other than an employee employed in connection with the selling of property or the negotiating of contracts for the employer) from the employer for travelling away from... and, for the purposes of subparagraphs (v), (vi) and (vii.1), an allowance received in a taxation year by a taxpayer for the use of a motor vehicle in connection with or in the course of the taxpayer's office or employment shall be deemed not to be a reasonable allowance (x)         where the measurement of the use of the vehicle for the purpose of the allowance is not based solely on the number of kilometres for which the vehicle is used in connection with or in the course of the office or employment, or          ... [7]      The amount received by the Appellant according to the agreement with the Union falls exactly within the above provision. ... The incidental to travel the Appellant is claiming has a more direct connection to his office or employment. ...

Counsel for the Appellant acknowledges that the Appellant still has various connections to Canada [4] but stressed that these connections only exist because the Appellant has family in Canada. ... These connections do not affect his ordinary intent to ordinarily reside outside of Canada. ... The Appellant was born in Ethiopia and has a deep emotional connection to the country; b.   ...

Coral was described as a corporation having substantial interests in Brazil in an attempt to justify use of the Brazilian currency in connection with projects undertaken by Coral. 4. ... I now turn to the other demands for particulars made by the appellant in connection with its "amended motion for particulars". ... In this connection the judgment of the Federal Court of Appeal in Gulf Canada Ltd. v. ...

He simply wants an indication as to whether you accept his offer or, in the alternative, whether you would, in fact, buy his interest for 1.2 million dollars so he can make long term plans in connection with his relationship with Colpo. ... (d) Albert John Alexander will cause Suncoast Estates Limited to pay Kenneth George Hutchins the sum of Fifty Thousand ($50,000) dollars for damages for breach of contract in connection with his dismissal as an officer of Suncoast Estates Limited, and in connection with an alleged agreement between Suncoast Estates Limited, and in connection with an alleged agreement between Suncoast Estates Limited, Kenneth George Hutchins and Albert John Alexander, which agreement was never consummated, and this payment is being made solely for the purpose of obtaining a complete and final release from the said Kenneth George Hutchins. ... There is no evidence that Suncoast as such had any agreement at all with Hutchins in connection with the sale of his shares — although it is quite possible that Alexander and Hutchins might have considered using this as a mechanism to accomplish the purpose of Alexander buying out Hutchins. ...

Some relevant factors in the formula are the number of days in a taxation year the vehicle is made available to the employee by the employer, the total number of kilometres driven during the days the car is available to the employee and whether substantially all of the distance travelled by the automobile in the days it was available to the employee is in connection with or in the course of the employee’s employment: paragraph 6(2)(d). ... In the case at bar, at least 85% of the distance travelled was in connection with Mr. ... The appeals for 1992 and 1993 will be allowed with costs and the assessments are referred back to the Minister of National Revenue for reconsideration and reassessment on the basis that substantially all of the distance travelled by the automobile in the total available days was in connection with Mr. ...

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. 3 6          The above comments are relevant in interpreting paragraph 6(1)(a). Parliament, has added the phrases “in the course of” and “by virtue of”, to the phrase “in respect of” in order to emphasize that only the smallest connection to employment is required to trigger the operation of the section. 7          Paragraph 6(1)(a) leaves little room for exceptions, but a few have surfaced in the jurisprudence. ...

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. ... “direct that a broad scope of inclusion be considered as to what constitutes a sufficient connection between the loss of employment and the amounts received” (see Anderson v. ...

To extend that to mean that someone whose revenue is based on the provision of legal services is employed in connection with the negotiation of contracts, distorts the clear meaning of those words. ... Furman is required to generate clients for the firm that his employment is "in connection with the negotiation of contracts". It is in connection with the provision of legal services. That is what he did, that is what he got paid for. [9]      Mr. ...