Search - connection

The reassessment arises from events flowing from the sale of certain of the appellant's assets used in connection with his office coffee supply business (the "coffee business"). ... No liabilities were assumed by the purchaser; therefore, the appellant was responsible for satisfying all liabilities incurred in connection with the coffee business. ... Concerning the travel expenses, the appellant in his notice of appeal pleads in the alternative as follows: In the alternative, should it be found that no business was carried on after the sale of the coffee services portion of the appellant's business, the amounts expended as set out in paragraph 5 were capital expenditures made in an attempt to acquire a benefit of an enduring nature toward the start-up of a new business entitling the appellant to capital loss treatment in connection with those amounts. ...

The only connection between the appellant and Bermuda appears to have consisted of the shared apartment and the visits thereto. ... In connection with training for qualification as a second mate, the appellant again studied at the Nova Scotia Nautical Institute. ... However, the evidence does not indicate that in so far as "ordered and customary living” is concerned the appellant's connection to Canada was less than his connection to Bermuda. ...

It was quite obvious that Friesen, with his connections in the City of Winnipeg, could dispose of the property quite readily. ... For the preparation of plans, specifications, briefs and other material in connection with, associated with or incidental to the above-mentioned activities. 5. For the attendance of representatives of the appellant at meetings with prospective tenants, and municipal, regulatory and other officials, committees and authorities in connection with, associated with or incidental to the above purposes. 7. ...

.: These appeals are in connection with two taxation years, 1991 and 1992. ... I have one further comment in connection with the 1991 return. I have shown that the Appellant deducted the full property taxes and mortgage interest on both houses in 1991. ... Turning to the 1992 taxation year, much of what I said in connection with 1991 has similar application in 1992. ...

The language of the provision is clear and does not impose the requirement that the payment originate with the employer. 16 The use of the words “in respect of” in the definition of retiring allowance has been recognized as conveying a connection between a taxpayer’s loss of employment and the subsequent receipt. In order for the retiring allowance provision to have real meaning, however, some limit must be placed on the ambit or scope of the required connection between a receipt and a loss of employment. ... What is implied from Pinard, J.’s analysis is that in determining the limit to be placed on the connection between a payment and a loss of employment, the appropriate test is to ask “but for the loss of employment would the amount have been received?” ...

If no statements or representations have ever been made in connection with a property, then that property cannot constitute a tax shelter. ... Accordingly, the existence of statements or representations in connection with a property is a necessary condition to a conclusion that the property constitutes a tax shelter. 38   The Appraisals and the Tax Opinion were prepared in advance of, and in connection with, the proposed marketing of TIP licences by or on behalf of TCL Trafalgar. ... In my view, neither of these propositions is correct. 41   The opening portion of the definition of tax shelter contains a requirement that statements or representations be made in connection with the property. ...

Smoke that their income was situated, not on a particular reserve, but rather on all of the reserves that had a connection to TCIG. ... Smoke with such reserve, for the reasons expressed above, this is not a particularly strong connection. ... Nevertheless, to the extent that ABL distributed i ts products to First Nations entities located on reserves, there would have been an indirect connection between those reserves and the services of Mr.  ...

That's where that connection was solidified. The Howards, one of them's a trainer. ... Brett Peters is one of Cudney's people and you know, very keen that way and the connection keeps up that way. ... And various others are all people who, at one time or another, have-- have, you know, been with us to the track or had a connection that way. ...

(usu. foll. by to, with) bring into relation with (with one another); establish a connection between (cannot relate your opinion to my own experience). [56]   [50]         In Nowegijick v.  ... Interestingly, in coming to this conclusion the SCC stated (at page 39) that the words import such meanings as “in relation to”, “with reference to” or “in connection with”. ... In my opinion, this is a sufficient link or connection to justify a finding that the appellant’s ABM operations "relate to" its other convenience store activities.   ...

(admitted)   (vi)    The Appellant's travel log was not consistent with the information stated on the invoices submitted to the Employer in connection with his expense account. ... (iii) that was a benefit in respect of the use of an automobile;  ...   6(1)(e) Standby charge for automobile – w here the taxpayer's employer or a person related to the employer made an automobile available to the taxpayer, or to a person related to the taxpayer, in the year, the amount, if any, by which     (i) an amount that is a reasonable standby charge for the automobile for the total number of days in the year during which it was made so available   exceeds   (ii) the total of all amounts, each of which is an amount (other than an expense related to the operation of the automobile) paid in the year to the employer or the person related to the employer by the taxpayer or the person related to the taxpayer for the use of the automobile;   6(2) Reasonable standby charge-- For the purposes of paragraph 6(1)(e), a reasonable standby charge for an automobile for the total number of days (in this subsection referred to as the "total available days") in a taxation year during which the automobile is made available to a taxpayer or to a person related to the taxpayer by the employer of the taxpayer or by a person related to the employer (both of whom are in this subsection referred to as the "employer") shall be deemed to be the amount determined by the formula   A/B × [(2% × (C × D) + 2/3 × (E- F)]   where   A is   (a) the lesser of the total number of kilometres that the automobile is driven (otherwise than in connection with or in the course of the taxpayer's office or employment) during the total available days and the value determined for the description of B for the year in respect of the standby charge for the automobile during the total available days, if     (i) the taxpayer is required by the employer to use the automobile in connection with or in the course of the office or employment, and   (ii) the distance travelled by the automobile in the total available days in primarily in connection with or in the course of the office or employment, and   (b) the value determined for the description of B for the year in respect of the standby charge for the automobile for the total available days, in any other case;   B is the product obtained when 1,667 is multiplied by the quotient obtained by dividing the total available days by 30 and, if the quotient so obtained is not a whole number and exceeds one, by rounding it to the nearest whole number or, where that quotient is equidistant from two consecutive whole numbers, by rounding it to the lower of those two numbers;   C is the cost of the automobile for the employer where the employer owns the vehicle at any time in the year;   D is the number obtained by dividing such of the total available days as are days when the employer owns the automobile by 30 and, if the quotient so obtained is not a whole number and exceeds one, by rounding it to the nearest whole number or, where that quotient is equidistant from two consecutive whole numbers, by rounding it to the lower of those two numbers;   E is the total of all amounts that may reasonably be regarded as having been payable by the employer to a lessor for the purpose of leasing the automobile during such of the total available days as are days when the automobile is leased to the employer; and   F is the part of the amount determined for E that may reasonably be regarded as having been payable to the lessor in respect of all or part of the cost to the lessor of insuring against   (a) the loss of, or damage to, the automobile, or   (b) liability resulting from the use or operation of the automobile.   6(1)(k) A utomobile operating expense benefit – where     (i) an amount is determined under subparagraph 6(1)(e)(i) in respect of an automobile in computing the taxpayer 's income for the year;   (ii) amounts related to the operation (otherwise than in connection with or in the course of the taxpayer's office or employment) of the automobile for the period or periods in the year during which the automobile was made available to the taxpayer or a person related to the taxpayer are paid or payable by the taxpayer's employer or a person related to the taxpayer's employer (each of whom is in this paragraph referred to as the " payor "),   and   (iii) the total of the amounts so paid or payable is not paid in the year or within 45 days after the end of the year to the payor by the taxpayer or by the person related to the taxpayer,   the amount in respect of the operation of the automobile determined by the formula   A – B   where   A is   (iv) where the automobile is used primarily in the performance of the duties of the taxpayer's office or employment during the period or periods referred to in subparagraph (ii) and the taxpayer notifies the employer in writing before the end of the year of the taxpayer's intention to have this subparagraph apply, 1/2 of the amount determined under subparagraph 6(1)(e)(i) in respect of the automobile in computing the taxpayer's income for the year, and   (v) in any other case, the amount equal to the product obtained when the amount prescribed for the year is multiplied by the total number of kilometres that the automobile is driven (otherwise than in connection with or in the course of the taxpayer's office or employment) during the period or periods referred to in subparagraph 6(1)(k)(ii), and     B is the total of all amounts in respect of the operation of the automobile in the year paid in the year or within 45 days after the end of the year to the payor by the taxpayer or by the person related to the taxpayer; and     248(1)  "automobile" means   (a) a motor vehicle that is designed or adapted primarily to carry individuals on highways and streets and that has a seating capacity for not more than the driver and 8 passengers;   but does not include   (b) an ambulance,   (b.1) a clearly marked emergency-response vehicle that is used in connection with or in the course of an individual's office or employment with a fire department or the police;   (c) a motor vehicle acquired primarily for use as a taxi, a bus used in a business of transporting passengers or a hearse used in the course of a business of arranging or managing funerals,   (d) except for the purposes of section 6, a motor vehicle acquired to be sold, rented or leased in the course of carrying on a business of selling, renting or leasing motor vehicles or a motor vehicle used for the purpose of transporting passengers in the course of carrying on a business of arranging or managing funerals, and   (e) a motor vehicle   (i) of a type commonly called a van or pick-up truck, or a similar vehicle, that has a seating capacity for not more than the driver and two passengers and that, in the taxation year in which it is acquired or leased, is used primarily for the transportation of goods or equipment in the course of gaining or producing income,   (ii) of a type commonly called a van or pick-up truck, or a similar vehicle, the use of which, in the taxation year in which it is acquired or leased, is all or substantially all for the transportation of goods, equipment or passengers in the course of gaining or producing income, or   (iii) of a type commonly called a pick-up truck that is used in the taxation year in which it is acquired or leased primarily for the transportation of goods, equipment or passengers in the course of earning or producing income at one or more locations in Canada that are   (A) described, in respect of any of the occupants of the vehicle, in subparagraph 6(6)(a)(i) or (ii), and   (B) at least 30 kilometres outside the nearest point on the boundary of the nearest urban area, as defined by the last census dictionary published by Statistics Canada before the year, that has a population of at least 40,000 individuals as determined in the last census published by Statistics Canada before the year.   ...