Search - connection

Naiberg also could not recall if there was a connection between the amount of the intercompany receivable and the amount WTC agreed to pay MPI for its shares in MCI. [25] In cross-examination, Mr. ... This suggests to me that rather than attempting to trace particular property, one must consider all the circumstances and determine whether it is reasonable to conclude that there is a connection between the diminishment of the property of one person and the increase in the property of another person. ... Medland had indirectly transferred property to his spouse. [138] In this case, the connection between the diminishment in the property of the subsidiaries and the increase in the property of the Appellants is clear because the parties agreed to and WTC effected transactions that caused the transfer of the Property at essentially a point in time on December 31, 2006 [50] and because the property that started in the subsidiaries is the same property that ended up in the Appellants (less the portion of the Property retained by WTC). [139] In conclusion, there is a clear connection between the reduction in the property of the subsidiaries and the increase in the property of the Appellants. ...

Barlow, Respondent Counsel attempted to highlight the Appellant’s potential awareness of the connection between the tax liabilities and his capacity as director. ...

The Crown attempts to establish the November 13, 1997 pick up date by: ·         testimony regarding the general mailing and courier procedures at the Canada Customs and Revenue Agency [2]; ·         testimony regarding the general pick up and delivery procedures at the courier company that delivered the notice; and ·         documents in connection with the delivery of this particular notice of assessment. ...

This was done in connection with a request for opinion submitted to the CRA’s advance income tax rulings directorate. ...

., did not provide for the performance of services but rather provided a guarantee of payment in connection with the buyback of the shares. ...

In the spring and summer of 1996, he also met a lawyer from the BJV firm to get a legal opinion on the arrangement (the donation program) to be used in connection with the raising of funds for ABLE. ...

Bell and Miss Dragovan which are admissions and those parts that go to credibility so long as the provisions of the Evidence Act were complied with when the witness was in the box in connection with such parts ...

It should be noted that the Appellant claims in the alternative that if the Court finds the funds were invested by him personally then he should be entitled to claim an allowable business investment loss in connection with same as they are business investment losses, or in further alternatives, ordinary business losses then capital losses in declining order. ...

The connections he had with the other investors were through Mr. Arbic who served basically as a phone booth among everyone. [36]     The witness relates that he had previously worked on a volunteer basis for Consuform, perhaps in 1991. ...

In this connection we refer to the decision of this Court in H.M. v. Placer Dome Inc.}, [1] decided after the trial judgment in the present case. ...