Search - connection

., 3 Tax A.B.C. 397. 5.06 The connection between the transaction at issue and the usual course of the taxpayer's business is another test that has been adopted in the case law. ...

At the present time Eckler has no further connection to the appellant or any related company. ...

In my view the overriding inference to be extrapolated from all this is that due to the very close family connection the whole matter had been dealt with in a very casual and most informal basis. ...

In connection with the amounts of penalties and interest relating to those unremitted source deductions assessed against the corporation, it was aknowledged by the appellant that they could properly be the subject matter of a valid claim against the appellant, the requirements of paragraph 227.1(2)(c) having been met in the present case. ...

It cannot mean the liability of taxpayer John Doe with whom Wesbrook has no connection or Wesbrook as a primary debtor in its own right without having acquired a liability as a result of its transaction with 466 and subsequent distribution of 466 property. ...

On examination for discovery, respondent’s counsel instructed the aforesaid Terence Hale not to answer ten questions respecting the nature of Transport’s tax liability for 1987 and the application of funds received by the Minister to Transport’s liability and also not to make any undertakings in connection therewith. ...

See also paragraph 139(1)(ae) of the Income Tax Act which includes as “personal and living expenses" and therefore not deductible for tax purposes, the expenses of properties maintained by the taxpayer for his own use and a benefit, and not maintained in connection with a business carried on for profit or with a reasonable expectation of profit. ...

S.C. 1970-71-72, c. 63) (the "Act"), are 248(1) definitions of "business" and “personal expenses", 8(1)(h), 8(2), 9(1), 18(1)(a) and (h) and 56(1)(a), which read as follows: 248(1) “business” includes a profession, calling, trade, manufacture or undertaking of any kind whatever and... an adventure or concern in the nature of trade but docs not include an office or employment; "personal or living expenses" includes (a) the expenses of properties maintained by any person for the use or benefit of the taxpayer or any person connected with the taxpayer by blood relationship, marriage or adoption, and not maintained in connection with a business carried on for profit or with a reasonable expectation of profit.... 8(1) In computing a taxpayer’s income for a taxation year from an office or employment, there may be deducted such of the following amounts as are wholly applicable to that source or such part of the following amounts as may reasonably be regarded as applicable thereto.... ...

(p) an outlay or expense to the extent that it was made or incurred by a corporation in a taxation year for the purpose of gaining or producing income from a personal services business (within the meaning assigned by paragraph 125(7)(d)), other than (i) the salary, wages or other remuneration paid in the year to an incorporated employee of the corporation, (ii) the cost to the corporation of any benefit or allowance provided to an incorporated employee in the year, (iii) any amount expended by the corporation in connection with the selling of property or the negotiating contracts by the corporation if the amount would have been deductible in computing the income of an incorporated employee for a taxation year from an office or employment if the amount had been expended by the incorporated employee under a contract of employment that required him to pay the amount, ana (iv) any amount paid by the corporation in the year as or on account of legal expenses incurred by it in collecting amounts owing to it on account of services rendered that would, if the income of the corporation were from a business other than a personal services business, be deductible in computing its income; Facts The essential facts are as follows. ...

He said that it comes within the definition in 248 of the Act which defines ’’retirement compensation arrangement" as follows:... retirement compensation arrangement” means a plan or arrangement under which contributions (other than payments made to acquire an interest in a life insurance policy) are made by an employer or former employer of a taxpayer, or by a person with whom the employer or former employer does not deal at arm’s length, to another person or partnership (in this definition and in Part XI.3 referred to as the "custodian") in connection with benefits that are to be or may be received or enjoyed by any person on, after or in contemplation of any substantial change in the services rendered by the taxpayer, the retirement of the taxpayer or the loss of an office or employment of the taxpayer, but does not include.... ...