Search - connection

It is quite clear that marketing campaigns cannot create lasting advantages and must necessarily be recurrent. [43]     In conclusion, regardless of whether the sales outlets were "corporate" stores or franchised stores, the advantage that was sought and could reasonably be obtained was an enduring connection to Rona's business structure. [44]     The fact that Rona acquired an ownership interest in Inovaco's capital stock merely for a short period is not relevant. ... They were losses incurred in connection with a capital venture.... I think it is clear that an expenditure incurred for the purpose of enabling a taxpayer to decide whether a capital asset should be acquired is an outlay or payment on account of capital.... [14] Counsel for the plaintiff relied on the judgments of Noël A.C.J. in Bowater Power Company Limited v. ...

I told Pertamina that I knew of potential sources of such funds and I travelled from Indonesia to Calgary and to San Francisco and Houston, for example, in connection with this Project ... I have no doubt that Roth had a considerable accumulation of knowledge as a result of his various business activities and connection with those expenses, which knowledge was of great interest to Pac-Rim LNG Joint Venture, leading ultimately to the sale of the five percent interest in the existing project to Pac-Rim LNG Inc, Bechtel Enterprises International LTD, Phillips Petroleum Canada Ltd and Daewoo Corporation.  ...

Notwithstanding the provisions of paragraph 2: (a)     copyright royalties and other like payments in respect of a deduction of any literary, dramatic, musical or artistic work (but not including royalties in respect of motion picture films and work on film, videotape or other means of reproduction for use in connection with television broadcasting; and (b)     royalties for the use of or the right to use computer software or any patent or for information concerning industrial, commercial or scientific experience (but not including any such information provided in connection with the rental or franchise agreement)          arising in a State and paid to a resident of the other State who is the beneficial owner of the royalties shall be taxable only in that other State ...

Counsel pointed out that it is not necessary that the outlay or expense should have resulted in a particular income, that it be in the year that it was expended or that there be a casual connection between the expenditure and a receipt. ... It is true that the expenditure need not produce a profit but in this case there was no connection between the expenditure in question and the Appellants’ other businesses. ...

The expert business skills, connections and profile of the persons involved at CMM were evident. ... Even if that were not the case, CMM had an enforceable legal right, reflected in tabs 19, 20, and 21 of Exhibit A-l, to call upon its major shareholders for up to $3,000,000 in connection with its guaranteed commitment to the Halifax Port Corporation. ...

If, for example, the same vehicle was used in the yard to perform functions in connection with maintenance and several trials that were being conducted concurrently, then the cost of operating that vehicle, including the fuel used in it, would properly be considered overhead. ... Nor is it necessary to do so, as it appears from the appellant’s reply to the respondent’s written argument that the issue only arises in connection with trials #48, #49 and #50, which I have found do not qualify as SRED ...

., or any affiliate or subsidiary designated by it, whereby it will, because of its knowledge of the property, have the right to act as leasing agent, and when applicable, as sales agent for the limited partnership and to have any listing, whether for lease or sale, in connection therewith, in the event of leasing of available space or any sale of the Swansea Shopping Centre Project comprising the business of the limited partnership and shall be entitled to payment in the amount and on the terms usually paid to independent leasing or sales agents operating in the city of Toronto performing similar functions. 10.01 Each subscribing limited partner shall provide by way of initial capital contribution, for each unit acquired, the sum of $100,000, the sum of $12,500 which was delivered at the time of delivery of the subscription and the balance by cash or certified cheque on or before April 15, 1986. 10.02 Each subscribing limited partner shall further provide by way of capital contribution, for each unit acquired, the further sum of $100,000 such amount to be paid by way of delivery of a promissory note issued in favour of H.L. ... We request that our concerns are passed on as soon as possible to those responsible for the excavation and that Consumers’ Gas be notified so that they can inspect the connection. ...

Other issues in connection with the terms of the original Partnership Agreement arose too, and so the Agreement of Purchase and Sale had annexed to it an Amended and Restated Partnership Agreement to be executed by the original partners prior to closing. ... , [17] Strayer J.A., the context of subsection 15(1.1) of the Act, said: In this connection we refer to the decision of this Court in H.M. v. ...

Such activities have absolutely no connection with the subject of the DAMDES project and make no contribution to the work done by several academics recruited for the project, who are very familiar with the technologies underlying the software examined in the feasibility study. ... Consequently, the following changes will be made in calculating your tax payable for 1989 and any other year that may be concerned:  -          the tax credit earned in connection with your interest in the partnership is refused;-          the business loss from this partnership, which you deducted, represents investment expenses that must be included in calculating the cumulative net investment loss. ...

The Appellant also argued that the Respondent had admitted both in the Reply and in the Agreed Statement of Facts that the excess amounts were payable. [9]            In connection with the contention that the interest payment was contingent, the Appellant relied on Justice Sharlow's comments in Wawang Forest Products Ltd. v. ... RESPONDENT'S SUBMISSIONS: [28]          Similarly, the Respondent acknowledged that the argument in connection with GAAR can be limited to a "misuse and abuse" analysis. ...