Search - connection

Without limiting the generality of the foregoing, the Assets include:               (i)         the Sites and Buildings;               (ii)        the Equipment;               (iii)       the Land Rights;               (iv)       the Current Assets;   (v)        the full benefit of the Contracts and all other contracts or commitments to which the Vendor or TransAlta Utilities Corporation or any of their Affiliates is entitled in connection with the Business including, without limiting the generality of the foregoing, all forward commitments of the Vendor or TransAlta Utilities Corporation or any of their Affiliates for supplies or materials entered into in the usual and ordinary course of Business whether or not there are any written contracts with respect thereto, but excluding, for clarity, contracts or commitments of a general nature that do not Primarily relate to the Business;   (vi)       the Warranties, if any;   (vii)      the Permits;   (viii)      computer software listed in Schedule 1.1(a);   (ix)       the goodwill of the Business including, without limiting the generality of the foregoing,   A.        ... It is the benefit and advantage of the good name, reputation, and connection of a business. ... The only real possible benefit was in connection with the one partner, Ontario Teachers Pension Plan Board, who may not have had to pay tax. ...

In addition, in later years the Conservatory Group provided mortgages to third-party purchasers in connection with its real estate business and invested large amounts of surplus funds in commercial paper ... It submits that the loan was made in connection with its overall profit-making scheme and was of a class of loan arrangement usually entered into by it. ... The exception carved out of these denial provisions permits the intercorporate dividend deduction in connection with term preferred shares acquired outside the “ordinary course of [the] business” carried on by the taxpayer ...

Krmpotic because of his connection to the numbered company. Precondition (3) has been met because the payment would have been for the benefit of Mrs. ...   [121]   Counsel argued that the Minister seemed to be thinking that the fact that these properties were written down somehow had a connection to the disposition of the property but the dates are completely different. ... Krmpotic was only in December of 2000 so there was no connection between the two. ...

Any claim for salary in connection with meetings away, other than the Confederation office or council must include a pay stub from the week in which the actual loss of salary occurred.     ... Expenses incurred in connection with activities held during a vacation period or on weekday programmed leave shall be reimbursed to the union member even if time is made up for.   ...   [57] In my opinion, this result is entirely in keeping with the situation of numerous volunteers who work for various charitable organizations and who render their services without being remunerated but are compensated for the expenses incurred in connection with the activities of these organizations, whether they be for profit or not. ...

Furthermore, the connection between the appellants and the Reserve is mitigated by the fact that the employment relationships between the appellants and NLS or OI were created merely for the purpose of obtaining a paragraph 87(1)(b) exemption. ... In Monias, the Federal Court of Appeal attached almost no significance to the location of branches of the banks from which the employer paid salaries and at which the employees’ accounts were credited, saying (at paragraph 57):   Where employees receive their employment income has little, if any, logical connection with the policy underlying section 87 ...   [146]      In the absence of any special circumstances that would tie the appellants’ work to a specific reserve, and in the absence of evidence of a significant connection between their work and the Six Nations Reserve or any other reserve, there is no basis for concluding that the taxation of their employment income from NLS or OI would result in the erosion of their entitlement to property they held as Indians on a reserve ...

NM I's proportionate share of revenues was subject to a further annual adjustment based on the cumulative expenditures made by NM I and Vidatron in connection with the marketing program. ... NM II's proportionate share of revenues was subject to a further annual adjustment based on the cumulative expenditures made by NM II and Vidatron in connection with the marketing program. ... Jones said that she provided no instructions to Grant in connection with his evaluation preparation and that Grant had come to her telling her what he needed in order to do so. ...

Colbran's attention so that he is fully aware of the steps being taken by the Landlord. [18]     He then produced a letter from Murray Holmes to 95 stating that he had searched their files and could not find any record of having acted for the Appellant in connection with the Cheesecake Café. [19]     The Appellant produced a copy of a letter dated March 29, 2000 to Tillyard & Partners, Inc. from The Cheesecake Cafe not bearing a signature but bearing the typed name of R.F. ... It is noted that Beeson appeared as the Respondent's only witness, having appeared as the result of being served with a subpoena so to do. [111] It is clear, from the evidence of both the Appellant and Beeson, that the Appellant was employed by the Beeson group to perform operational services in connection with the Victoria Cheesecake Café. [112] I accept the Appellant's evidence that when he signed the subscription for shares of 95 and signed the CONSENT TO ACT AS A DIRECTOR, he expressly directed Ross, the lawyer who produced the "shelf" company not to use those documents until he had become a resident of British Columbia and until other conditions specified by him were fulfilled. ... In that company Wheeliker signed statements of particulars in connection with a Royal Bank of Canada account as "director" and the Agreement Re: Operation of Account as "director" of the company. ...

The only reimbursement by CKUA for expenses incurred by Burton or other account executives was in connection with travel outside their designated sales territory or in the instance where Burton was reimbursed the cost of a civic luncheon because the General Manager (GM) of CKUA was unavailable and had requested her to attend on his behalf and represent CKUA. ... Burton used the computer at the CKUA office in connection with making her sales but that was never a requirement of her contract. ... Her expenses in connection with attending a luncheon- at which she substituted for the GM of CKUA- were paid by the appellant. ...

The distinction was pointed out by Davies J in connection with similar words used in s.26AAA(4) of the Act in Barnsdall v. ... The Commissioner is required to be satisfied not merely of a connection between a taxpayer and the person to whom the taxpayer transferred, but also of the fact that they were not dealing with each other at arm's length. A finding as to a connection between the parties is simply a step in the course of reasoning and will not be determinative unless it leads to the ultimate conclusion. ...

A number of cases were cited in connection with the arm's length issue, including Peter Cundill & Associates Limited v. ... Moreover, the lengthy reasons of the Judge below fail to disclose any misconduct anterior to the litigation that could be imputed to the Commission and be considered as sufficiently serious and as having a close enough connection with the litigation to warrant such an award. ... (c) a payment of a dividend contrary to section 42,... are jointly and severally liable to restore to the corporation any amounts so distributed or paid and not otherwise recovered by the corporation.... 118(4) Recovery A director liable under subsection (2) is entitled to apply to a court for an order compelling a shareholder or other recipient to pay or deliver to the director any money or property that was paid or distributed to the shareholder or other recipient contrary to section 34, 35, 36, 41, 42, 44, 124, 190 or 241. 118(5) Order of court In connection with an application under subsection (4) a court may, if it is satisfied that it is equitable to do so, (a) order a shareholder or other recipient to pay or deliver to a director any money or property that was paid or distributed to the shareholder or other recipient contrary to section 34, 35, 36, 41, 42, 44, 124, 190 or 241;... ...