Search - connection

The context for the purpose of the interpretation of a treaty shall comprise, in addition to the text, including its preamble and annexes: (a) any agreement relating to the treaty which was made between all the parties in connexion with the conclusion of the treaty; (b) any instrument which was made by one or more parties in connexion with the conclusion of the treaty and accepted by the other parties as an instrument related to the treaty. 3. ...

(c) “Point of measurement” with respect to: (i) crude oil and crude naphtha means the production tanks, of the Lessee to which any well on the said lands is connected; (ii) absorption gasoline and/or natural gas means the point of connection with the gas gathering system connected to the well. ... (c) “Canadian resource property” of a taxpayer means any property acquired by him after 1971 that is (i) any right, licence or privilege to explore for, drill for or take petroleum, natural gas or related hydrocarbons in Canada, (ii) any right, licence or privilege to (A) store underground petroleum, natural gas or related hydrocarbons in Canada, or (B) prospect, explore, drill or mine for minerals in a mineral resource in Canada, (iii) any oil or gas well in Canada, (iv) any rental or royalty computed by reference to the amount or value of production from an oil or gas well in Canada, (v) any rental or royalty computed by reference to the amount or value of production from a mineral resource in Canada, (vi) any real property in Canada the principal value of which depends upon its mineral resource content (but not including any depreciable property used or to be used in connection with the extraction or removal of minerals therefrom), or (vii) any right to or interest in any property (other than property of a trust) described in any of subparagraphs (i) to (vi) (including a right to receive proceeds of disposition in respect of a disposition thereof); [Emphasis added.] ...

It read: 2. (1) In this Act, and in any regulations made hereunder, unless the context otherwise requires, (r) “personal and living expenses” shall include inter alia — (i) the expenses of properties maintained by any person for the use or benefit of any taxpayer or any person connected with him by blood relationship, marriage or adoption, and not maintained in connection with a business carried on bona fide for a profit and not maintained with a reasonable expectation of a profit. ... Apart from specific legislation in a taxing statute, I know of no law which imposes an obligation upon a lender to demand the payment of interest in connection with a loan granted by the lender to a borrower, and if the lender does not require the payment of interest, the borrower is under no obligation to pay interest. ...

., 2015 FCA 52 at paragraphs 3 to 6.] and therefore as a general proposition it is the facts directly or indirectly [Footnote: One example of a fact that is indirectly relevant is a fact that is relevant to credibility.] relevant to that core issue that may be explored in an oral examination for discovery. [26] With respect to the degree of connection that is required by the phrase “relevant to any matter in issue in the proceeding”, [Footnote: Subsection 95(1).] in Lehigh the Federal Court of Appeal states at paragraph 34: The jurisprudence establishes that a question is relevant when there is a reasonable likelihood that it might elicit information which may directly or indirectly enable the party seeking the answer to advance its case or to damage the case of its adversary, or which fairly might lead to a train of inquiry that may either advance the questioning party’s case or damage the case of its adversary. [27] Recently, in Madison Pacific Properties Inc. v. ... More precisely, questions that constitute a fishing expedition are not proper questions either because they are overly broad and/or an abuse of the discovery process or because they have no connection to the matters in issue in the proceeding, or both. ...

The Appellants argue that the right of setoff arises when there is a mutuality of parties and a connection between the claims made by each. [2] This right was described by Middleton J. as follows: [3] There is, however, another equity which has sometimes been called ‘set-off but which does not in any way depend upon the statute, which arises when the claims are upon the same contract or are so interwoven by the dealings between the parties that the Court can find there has been established a mutual credit, or an agreement, express or implied, that the claims should be set one against the other. ... Without such connection, an equity to set-off will not necessarily be granted, an intention to liquidate a debt by the other would have to be found (see s. 130, Canadian Encyclopaedic Digest (Western) 3rd edition, Debtor and Creditor). ...

The Appellant has failed to establish any connection between these expenses and the Barcrest sale. ... Minister of National Revenue (1985), 85 D.T.C. 455 (T.C.C.). 27 27(1985), 85 D.T.C. 272 (T.C.C.), at 274. 28 28(1995), 96 D.T.C. 1686 (T.C.C.), at 1689 29 Paragraph 54(g)(iii)- Income Tax Act 30 Exhibit R-16- Appellant’s accountants calculations. 31 Exhibit R-16- page 2. 32 Exhibit R-16- page 2 33 Exhibit R-7- Letter dated April 27, 1989 from Helson Kogon to the Appellant enclosing statements setting out the amounts received and paid out in connection with the purchase and sale of Barcrest and the Nowak farm 34 l‘he Appellant’s testimony with respect to Furlong’s involvement is inconsistent, if not contradictory. ...

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. [42] According to the Brandon Affidavit, on January 15, 2016, the Respondent sent to the Appellant a copy of a 2016 CRA position paper prepared by the auditors responsible for the audit of the Program and the audit reports of the Appellant dated June 21, 2004 and July 11, 2005. ...

Loss (2) Subject to section 31, a taxpayer's loss for a taxation year from a business or property is the amount of the taxpayer's loss, if any, for the taxation year from that source computed by applying the provisions of this Act respecting computation of income from that source with such modifications as the circumstances require.... 40(2)(f) a taxpayer's gain or loss from the disposition of (i) a chance to win a prize or bet, or (ii) a right to receive an amount as a prize or as winnings on a bet, in connection with a lottery scheme or a pool system of betting referred to in section 205 of the Criminal Code is nil;... 248(1) business includes a profession, calling, trade, manufacture or undertaking of any kind whatever and, except for the purposes of paragraph 18(2)(c), section 54.2, subsection 95(1) and paragraph 110.6(14)(f), an adventure or concern in the nature of trade but does not include an office or employment; (commerce) X. ... The right to receive an amount as winnings on a bet is not earned in connection with a lottery scheme or a pool system of betting referred to in section 205 of the Criminal Code. ...

Loss (2) Subject to section 31, a taxpayer's loss for a taxation year from a business or property is the amount of the taxpayer's loss, if any, for the taxation year from that source computed by applying the provisions of this Act respecting computation of income from that source with such modifications as the circumstances require. (...) 40(2)(f) a taxpayer's gain or loss from the disposition of (i) a chance to win a prize or bet, or (ii) a right to receive an amount as a prize or as winnings on a bet, in connection with a lottery scheme or a pool system of betting referred to in section 205 of the Criminal Code is nil; (...) 248(1) business includes a profession, calling, trade, manufacture or undertaking of any kind whatever and, except for the purposes of paragraph 18(2)(c), section 54.2, subsection 95(1) and paragraph 110.6(14)(f), an adventure or concern in the nature of trade but does not include an office or employment; (commerce) IX. ... The right to receive an amount as winnings on a bet is not earned in connection with a lottery scheme or a pool system of betting referred to in section 205 of the Criminal Code. ...

The context of the provision is to expand the definition of a series which is an indication against a narrow interpretation. [45] In fact, at paragraph 56 the SCC stated that the language of s.248(10) allows either a prospective or retrospective connection of a related transaction to a common law series. [46] In determining whether a related transaction was done in contemplation of another series, the SCC in Copthorne, paragraphs 46-47 stated that: [46]………. “The Court is only required to consider” whether the series was taken into account when the decision was made to undertake the related transaction in the sense it was done “in relation to” or “because of” the series. [47] Although the “because of” or “in relation to” test does not require a strong nexus, it does require more than a “mere possibility” or a connection with “an extreme degree of remoteness”…… Each case will be decided on its own facts…. ...