Search - connection

It had no connection to Canada. Why bring it here, subject that uranium to Canadian tax when it never was from Canada in the first place? ... Well, I said: “Please review the quantity and delivery date in connection with the BfE approval.” ... The losses result from the ps activity and the ps activity itself has no connection with the resource activity of the Appellant. ...

In this regard, the Tax Court judge found at page 15 of his decision that "there is no evidence that the fishing activity of the Company which gives rise to the incomes of the Appellants has any close connection with the Reserve, or any historic, social or cultural connection with either the Band or the Reserve". ...

The Minister says that it is not because no Notice of Objection was filed under section 165 of the Act. 540 has also appealed from its assessments for 1990 and 1991, claiming to be entitled to carry a non-capital loss forward from 1988 and apply it to those years. [3]            The expenses disallowed by the Minister are interest on certain loans, and in the case of Novopharm's 1987 year, a financing fee of $500,000 and a consulting fee of $200,000, both paid in connection with one of those loans. facts [4]            The events giving rise to the appeals were a carefully orchestrated series of transactions designed to permit Novopharm to take advantage of the accumulated losses of $11,634,134 and the unused Canadian exploration and development expenses (CEDE) totalling $10,724,370 of a company called Royal Scot Resources Ltd. ... Fogler, Rubinoff, $75,549.84 for their services in connection with these transactions. ...

Liquor Control Act, R.S.N.S. 1989, c. 260, s. 18                 18             All property, whether real or personal, all money acquired, administered, possessed or received by the Commission and all profits earned in the administration of this Act, shall be the property of Her Majesty in right of the Province, and all expenses, debts and liabilities incurred by the Commission in connection with the administration of this Act shall be paid by the Commission from the money received by the Commission under such administration. Nova Scotia Hospital Act, R.S.N.S. 1989, c. 313, s. 4                 4               The Hospital and all the real and personal property and assets of every kind held and enjoyed in respect to or in connection with the Hospital are vested in Her Majesty in right of the Province. ...

It is nonetheless a strong confirmation that the intended purpose and scope of Articles I and IV of the US Treaty were that the treaty apply to those bearing full tax liability in either of the contracting states based upon the nature and extent of their connections with that country ... It is important to note that the solutions developed in this report do not exclude the possibility that Member countries may in their bilateral relations develop different solutions to the problems of double taxation which may arise in connection with partnerships.   ...

Clause 6 of the contract provided that: The contractor shall at his own expense obtain all licences and permits that may be required for or in connection with the use of the said facilities for the purposes aforesaid. ... In Nomad Sand & Gravel Ltd., supra, the nature of the taxpayer's business did not give the taxpayer any on-going connection with its customers that would have allowed the taxpayer to demonstrate it had to provide future services. ...

All security now or at any time hereafter held by the bank for the payment of any debt or liability of the customer (the said security being hereinafter called “the security”), including, without limiting the generality of the foregoing, security by way of warehouse receipt or bill of lading or under section 88 of the Bank Act, together with all property covered by or comprised in the security (the said property being hereinafter called "the property"), and all proceeds of the security and of the property, shall be continuing collateral security for the payment of such debt or liability and also for the payment of interest thereon calculated according to the bank's usual custom, and of all costs, charges and expenses of or incurred by the bank in connection therewith, whether in protecting, preserving, realizing or collecting the security or the property or attempting so to do or otherwise, and interest thereon at the rate and calculated in the manner aforesaid, all of which the customer agrees to pay to the bank. 4. ... The Court said the following at page 373 (D.T.C. 6284): In this latter connection, counsel for the respondent submitted that by virtue of the payments the respondent was ipso facto subrogated to the employee’s claim for wages. ...

Another pertinent provision, paragraph 4(b) reads, in part, as follows: the investor agrees to pay to the company by December 31, 1987 in connection with this agreement amounts equal to 20 per cent of the amount of E expenditures set out in clause 1 hereof. ... Finally, it appoints Northcor as the agent of the partnership for all matters in connection with any application for PIPs. ...

Loewen on the redemption of a debenture which had been issued in connection with a scientific research tax credit (“SRTC”). ... There was no private gallery sponsor of Morrisseau in the intervening years because his personal lifestyle did not encourage that kind of professional connection. ...

In the Bill of Costs above referenced, the Respondent did not include the expenses incurred in connection with JS, the person tendered as its second expert witness whose qualifications were not accepted by the Court. [3]              Notwithstanding that the Respondent has only claimed Tariff costs, the Appellants, in its initial submissions and subsequently in reply submissions, argues that such fees should not be allowed or dramatically reduced on essentially the following basis: 1.                  ... Moreover, as the Respondent has pointed out, section 241 of the Income Tax Act provides that the names of such taxpayers and other information pertaining to them is confidential and so the Court would not even be in a position to know who they are. [92]         Section 241 reads as follows: 241. (1)     Provision of information- Except as authorized by this section, no official or other representative of a government entity shall (a) knowingly provide, or knowingly allow to be provided, to any person any taxpayer information; (b) knowingly allow any person to have access to any taxpayer information; or (c) knowingly use any taxpayer information otherwise than in the course of the administration or enforcement of this Act, the Canada Pension Plan, the Unemployment Insurance Act or the Employment Insurance Act or for the purpose for which it was provided under this section. (2)   Evidence relating to taxpayer information  - Notwithstanding any other Act of Parliament or other law, no official or other representative of a government entity shall be required, in connection with any legal proceedings, to give or produce evidence relating to any taxpayer information. (3)   Communication where proceedings have been commenced- Subsections (1) and (2) do not apply in respect of (a) criminal proceedings, either by indictment or on summary conviction, that have been commenced by the laying of an information or the preferring of an indictment, under an Act of Parliament; or (b) any legal proceedings relating to the administration or enforcement of this Act, the Canada Pension Plan, the Unemployment Insurance Act or the Employment Insurance Act or any other Act of Parliament or law of a province that provides for the imposition or collection of a tax or duty. [93]         It is obvious there is no exception for accessing such confidential information for the purposes of allocating costs above. [94]         More fundamental however, is the principle that persons who have no ability to influence the conduct of an appeal cannot be liable for costs. ...