Search - connection

Results 31 - 40 of 3277 for connection
TCC

Bombardier Inc. v. The Queen, 2011 TCC 48

Question 6: Is there a connection between the method of recognizing income associated with long-term contracts and the characterization of the amounts received from customers as advances?                                                                                          ... Question 6: Is there a connection between the method of recognizing income associated with long-term contracts and the characterization of the amounts received from customers as advances?   ... In fact, chapter 3400, more specifically at paragraphs 3400.06 to 3400.15, clearly makes the connection between recognition of income and performance of the work ...
TCC

Blackmore v. The Queen, 2013 DTC 1213 [at at 1147], 2013 TCC 264, aff'd 2014 DTC 5123 [at 7316], 2014 FCA 210

They have some sense of connection.  There's a structure to it, right, so organizations have a sense of structure, and that typically includes some notion of who belongs and who doesn't belong.  ... Cragun noted that the LDS Church today continues to disavow any connection to Mormon fundamentalists or groups that continue to practise polygamy, as Bountiful does.   ...   [256]    I see no logical connection between these two phrases “beneficial ownership” and “in their own right.” ...
TCC

Wall v. The Queen, 2019 TCC 168, aff'd on other grounds 2021 FCA 132

Work expended on or in connection with the property realized. If effort is put into bringing the property into a more marketable condition during the ownership of the taxpayer or if special efforts are made to find or attract purchasers (such as the opening of an office or advertising) there is some evidence of dealing in the property. 5.   ... The Queen, [1978] C.T.C. 378, 78 D.T.C. 6281 (F.C.A.), the Chief Justice of the Federal Court stated at 384 (D.T.C. 6285) that the term “secondary intention”:... does no more than refer to a practical approach for determining certain questions that arise in connection with “trading cases” but there is no principle of law that is represented by this tag. ... Wall was in the business of developing properties and he developed the Three Homes as part of this business. (4) Work expended on or in connection with the property realized [162]   It is apparent that Mr. ...
TCC

MacDonald v. The Queen, 2018 TCC 55

Further, in this appeal, it has to be noted that counsel for the Appellant did not ask permission to make submissions on costs at the close of the hearing on February   16,   2017. [22]   However, I   do agree with the Appellant that a party having made a valid settlement offer and having obtained a judgment as favourable as or more favourable than the settlement offer has a presumptive right to substantial indemnity costs. [23]   The Federal Court of appeal in Venngo Inc v Concierge Connection Inc (Perkopolis), 2017   FCA   96, 146   CPR   (4th)   182 [Venngo], reviewing Rule   420 of the Federal Courts Rule, the language of which is similar to the language of subsection   147(7) of the Rules, stated: 88   I agree with Venngo that the Federal Court committed a legal error in its assessment of CCI’s written offer to settle dated October 23, 2015. ...
TCC

Rudolph v. The King, 2024 TCC 148

Work expended on or in connection with the property realized. If effort is put into bringing the property into a more marketable condition during the ownership of the taxpayer or if special efforts are made to find or attract purchasers (such as the opening of an office or advertising) there is some evidence of dealing in the property. 5. ...
TCC

Leonard v. The Queen, 2021 TCC 33, rev'd 2022 FCA 195

Work expended on or in connection with the property realized. If effort is put into bringing the property into a more marketable condition during the ownership of the taxpayer or if special efforts are made to find or attract purchasers (such as the opening of an office or advertising) there is some evidence of dealing in the property. 5. ...
TCC

ONEnergy Inc. v. The Queen, 2016 TCC 230, rev'd 2018 FCA

This seems to be the essence of the connection claimed, and it is very much a “but for” connection. [20]         What I suggest is at issue in looking at this from a strictly textual broad interpretation of “in connection with” is whether a corporation can ever be considered to incur a “personal expense” or is every expense “in connection” with its business? ... No, not in the sense I find a connection is required given the context and purpose. ... I emphasize it is the connection that is paramount, not the timing of the activity. ...
TCC

Castela v. The Queen, 2005 DTC 781, 2005 TCC 109 (Informal Procedure)

In the general exclusion any connection, in the broadest sense, should suffice. ... The subject provision of the Act does not speak of such potential connections. ... Nor was it in connection with her duties of employment. Rather, it was in connection with her profession. ...
TCC

Cunningham v. The Queen, 2005 TCC 455 (Informal Procedure)

It is unlikely that the program in these circumstances is “taken” in connection with the employment ... I agree with counsel for the Crown that the words “in connection with” are broad but in my view an insubstantial connection is not sufficient ... I note that it is not sufficient to have a connection to a field of endeavour or profession. ...
TCC

Reiner v. The Queen, 2005 DTC 308, 2005 TCC 115 (Informal Procedure)

Nor was it in connection with her duties of employment. Rather, it was in connection with her profession. ... Nor is it even "in connection with" School District No. 23 any more than the calling of being a janitor is in connection with School District No. 23. ... Connection ("connexion") is: The action of connecting; the condition of being connected. ...

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