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Results 2851 - 2860 of 3280 for connection
TCC

Marzen Artistic Aluminum Ltd. v. The Queen, 2014 DTC 1145 [at at 3433], 2014 TCC 194, aff'd 2016 DTC 5018 [at 6600], 2016 FCA 34

He has key contacts and personal connections with significant Canadian builders who were entering the southern California real estate market.  ... A I’m satisfied that that would have been-- there’s some connection between the two. [30] [Emphasis added.] [62]         Mr. ... Csumrik out to have had personal connections with the Canadian developers who had projects in the southern California high-rise market, at trial, he said he only knew ‘of’ them, apparently from as tenuous a connection as having lived in False Creek during a time when they may have had projects there. ...
TCC

Burlington Resources Finance Company v. The Queen, 2017 TCC 144

The Appellant contends it would not be reasonable to expect a request would be honoured by the Parents with respect to highly sensitive information, such as the requirements of financial regulatory regimes governing the Parents, nor to documents that lack any connection with the Appellant (eg. other guarantees and comfort letters). ... With respect to the request for documents to which the Appellant is not a party, I see the issue of reasonable expectation less in terms of the lack of connection as I do in terms of whether or not the document is indeed relevant. ... Question 1578- Whether BRI or Burlington filed with the SEC a copy of the July 24, 2000 guarantee and the date that it was filed with the SEC. [404]    Burlington responded that it understands that the guarantee was provided to the SEC in connection with the correspondence listed at Items 48 and 49 of the Appellant's List of documents. ...
TCC

Mazraani v. M.N.R., 2016 TCC 65

MICHAUD: I would say we would strongly recommend--- JUSTICE ARCHAMBAULT: If someone had connection with the mafia? ... The best person to testify to describe his role in connection with Mr.  ... In addition, the Company would have taken steps to get rid of an assistant who had a bad reputation or connections with criminal organizations. ...
TCC

Adler v. The Queen, 2007 DTC 783, 2007 TCC 272

In order to compete with other service providers, Telus introduced high-speed internet connection. ... The free pass was provided to Adler upon his promotion to Director without any consideration of its use in connection with his employment duties. ... Any benefit accruing to Telus was incidental and the connection between Barry’s free parking privileges and the duties performed by her in the course of employment was – for the most part – nebulous ...
TCC

McKeown v. The Queen, docket 96-2732-IT-G

Moreover, the appellant did not make any connection between being a member of a general partnership and being an owner of a business. ... However, he could not explain the connection between the two documents. ... Omzar Technologies Inc. also had financial statements for 1994 that were prepared in connection with its bankruptcy. [225]        Mr. ...
TCC

Québecor Inc. v. The King, 2023 TCC 142

The ACB was reduced from $191,833,983 to $1; [4] 2- The Minister added a $95,916,990 capital gain to Quebecor’s income in connection with the disposition of 44,821,024 common shares of Abitibi Consolidated; [5] and 3- The Minister disallowed Quebecor’s $95,916,992 capital loss in connection with the disposition of 44,821,024 common shares of Abitibi Consolidated. [6] II. ... The second capital loss was realized by 3662527 in connection with the shares that it held in Vidéotron Telecom. [132] [101] Quebecor admits that, in strictly economic terms, there were considerable unrealized losses at the time when the series of transactions took place. ... Quebecor was thus able to realize capital losses of $95,916,992 in 2007 and $95,916,991 in 2010 in connection with these shares instead of realizing a $95,196,990 capital gain in 2007 and no capital loss in 2010. ...
TCC

McCoy v. The Queen, 2003 DTC 660, 2003 TCC 332

REPRESENTATIONS AND WARRANTIES 10.01    Each of Trafalgar Capital and Trafalgar Research hereby represent and warrant to the Purchaser that the following representations and warranties are true and correct as of the date hereof, and each acknowledges that the Partnership is relying on such representations and warranties in connection with the performance of its obligations under this agreement:... ... He agreed that he was not an accredited appraiser but that he had done in excess of 275 software appraisals of which about one-third or one-half were in connection with software tax shelters. ... In determining contingency, what matters is the connection between the guarantees given by Trafalgar Capital and Trafalgar Research and the debt, if any, of the limited partners to Trafalgar Capital. ...
TCC

Sommerer v. The Queen, 2011 DTC 1162 [at at 845], 2011 TCC 212, aff'd 2012 FCA 207

Jenkins in connection with this sale of Vienna shares:   I will transfer to you upon issuance of the share certificate in your name any dividend and share allocation rights. ... The SPF received two cheques in the amounts of $316,584 and $539,007 in connection with this sale.   ... In other words, if the literal French meaning of the phrase "ou les biens qui leur sont substitués" were to determine the scope of s. 75(2)(a)(i), it would remove any temporal connection between the transfer of property by a person to the trust and the attribution of income from the trust property (including previously‑owned trust property) to that person ...
TCC

LeCaine v. The Queen, 2009 TCC 382

It seems to me that the decision to attend any funeral is a personal decision and the reason that a person attends a funeral will depend on the relationship or connection of that person to the deceased. Some people who had a direct connection or relationship with the deceased would presumably attend the funeral to grieve or for closure. Others who had an indirect connection would presumably attend to express condolences and show support for family and friends of the deceased and others may attend to show respect. ...
TCC

Auto Maculate Inc. v. The Queen, 2020 TCC 105 (Informal Procedure)

Wahab contends that he and his wife were given a $3,000 rebate cheque from their realtor in connection with the purchase of the Yarrow Property in late 2009. ... This amendment concerned the character of certain payments they received in 2009 and 2010 in connection with arrangements they made with North American Financial Group (“NAFG”). ... Voung then agreed the latter would provide consulting services to Auto Maculate in connection with what Mr.  ...

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