Search - connection

Results 251 - 260 of 3280 for connection
TCC

Commission Scolaire du Fer v. The Queen, 2004 TCC 702

  [20]     However, those independent connections were not made and there is still only one electric meter for the entire real property complex. ... Furthermore, in the agreement signed on January 22, 1991, paragraph 11 specifically provides that the parties will take the necessary measures to change the electrical connections so as to make Blocks “C” and “D” independent. ... That provision sets out that measures will be taken to change the electrical connections so as to enable all the facilities in Blocks “C” and “D” to function independently. ...
TCC

Emergis Inc. v. The Queen, 2021 TCC 23, rev'd 2023 FCA 78

The Supreme Court of Canada described the words “in respect of” as probably the widest expression intended to convey some connection between the two related matters (see Nowegijick v. The Queen, (1983) 1 S.C.R. 29). [69] However, as highlighted by the Respondent, it is still necessary to find a connection between the U.S. tax paid and the dividend income received. ... Clearly, there has been two sorts of reliefs obtained here but the question here is whether the deduction claimed under subsection 20(12) and section 113 were for the same source of income. [82] I do find a connection between the dividend and interest payment. ...
TCC

Dugan v. The Queen, 2011 DTC 1202 [at at 1163], 2011 TCC 269 (Informal Procedure)

It is not what might be referred to as an aboriginal business and has no direct connection with a reserve. ... That is, the work connection to the reserve was not prejudiced by living on the outer edge of a reserve. Similarly, one’s personal, living connection to a reserve may not be prejudiced by living on the outer edge of a reserve ...
TCC

Edward Orlak v. Minister of National Revenue, [1989] 1 CTC 2063

The appellant argues that Revenue Canada had reports of all such income because the Bank of Canada had his social insurance number in connection with the bonds and International Nickel Company, the employer, had his social insurance number on a TD1 form. ...
TCC

Jaro W.R. Osmak, Luba Osmak and Maria Osmak v. Minister of National Revenue, [1988] 1 CTC 2441

In support of his contention counsel for the appellants submitted to the Court four documents-- three of which allegedly were "reporting letters" from firms of solicitors involved with the sale transactions noted above, and one of which was a form of personal guarantee from the three appellants to a bank in connection with the provision by that bank of certain credit. ...
TCC

Richard Perren & Co. v. R., [1997] 2 CTC 2501, 97 DTC 1227

A discovery of a Revenue Canada person, who did an audit, did not reveal any connection between the payment and the supply of product. ...
TCC

Laquerre v. The King, 2022 TCC 90

He did not personally receive these documents after his lawyer had made an ATIP request in 2009. [3] This Court is not satisfied, on a balance of probabilities, that the new documents brought to its attention by the appellant in these motions establish that there was fraud on the part of the CRA or the Department of Justice in connection with the settlement reached with the appellant’s trustee in bankruptcy. [4] This Court is also not satisfied, on a balance of probabilities, that these documents had any impact on the terms of the settlement or the 2014 discontinuances. ...
TCC

Stigen v. The Queen, 2008 DTC 4342, 2008 TCC 405

That is a connection to the reserve but, in my view, a relatively weak one. ... Certainly there is a connection, but there appears to be a stronger connection to the commercial mainstream. ... The Appellant emphasizes the extent of Peace Hills’ investment with a First Nations connection, though cannot specify the on-reserve element. ...
TCC

Kruco Inc. v. R., 98 DTC 1568, [1998] 3 CTC 2319 (TCC)

Sheppard’s firm were provided in connection with that goal, I cannot conclude that Mr. ... Sheppard’s firm may have been incurred in connection with legal proceedings taking place in the Bahamas and in Panama. ... The parties identified fees amounting to $114,773 as having been incurred in connection with the Bernard J. ...
TCC

Blier c. La Reine, 2003 TCC 505 (Informal Procedure), briefly aff'd 2004 DTC 6726, 2004 FCA 236

At the provincial level, there had been out-of-court agreements. [18]     On cross examination, it was admitted that counsel for the appellants had asked the federal tax authorities to put the cases on hold pending the decision of Revenu Québec. [19]     In connection with his case withRevenu Québec, he pleaded guilty to a charge of filing a false return. ... According to paragraph 3 of Information Circular IC 89-4, dated August 14, 1989, the definition of a tax shelter depends entirely on the reasonable inferences to be drawn from representations made in connection with the property. ... He had previously advised her regarding an investment in connection with her son's education. ...

Pages