Search - connection
Results 3051 - 3060 of 3266 for connection
TCC
Laflamme v. The Queen, 2008 DTC 482, 2008 TCC 255
[10] The parties to this litigation saw fit to file a Partial Agreed Statement of Facts, which summarizes all the transactions that took place at this stage of the events (that is to say, starting on December 18, 1996) in connection with the transfer of the IRSL shares, and involving the Trust, the newly created 332 Canada, and the management companies held by the Appellant, his son Jean Laflamme and André Lamothe ...
TCC
Blais v. The Queen, 2011 DTC 1008 [at at 55], 2010 TCC 195 (Informal Procedure)
There were no detailed explanations about the use of the money. [69] [68] No contract was filed in evidence in connection with this loan and with the obligations between Mr. ...
TCC
Rouleau c. La Reine, 2007 DTC 1619, 2007 TCC 338 (Informal Procedure)
Cusson laid out 100% of the cost of the investment in December 1989, but then went to collect a cheque in connection with a buyback for 50% of that cost a few weeks later in January 1990 ...
TCC
Black v. The Queen, 2014 DTC 1046 [at at 2882], 2014 TCC 12, briefly aff'd 2014 FCA 275
By a series of reassessments, the last of which (the "Reassessments") is the subject of this appeal, the Minister of National Revenue assessed tax against the applicant under Part I of the Income Tax Act (the " Act ") on the following amounts [referred to in these reasons as "Assessed Items"]: (a) $2,862,385 on account of incomes from the duties of offices and employments performed by the applicant outside of Canada; [2] (b) $90,291 on account of the value of the benefit assumed by the Minister to have been received by the applicant from 10 Toronto Street Inc ("10 Toronto") for the security paid in connection with the applicant's home at 26 Park Lane Circle, Toronto; (c) $87,834 on account of the value of the benefit assumed by the Minister to have been received by the applicant from The Ravelston Corporation ("Ravelston") for an amount paid to John Hillier; (d) $326,177 on account of taxable dividends received by the applicant; (e) $28,035 on account of interest and other investment income received by the applicant; (f) $365,564 on account of benefits which the Minister assumed that the applicant was deemed to have received under subsection 15(1), subsection 15(9) and subsection 80.4(2) of the Act in respect of indebtedness owed by him to Conrad Black Capital Corporation ("CBCC"); and (g) $1,367,055 on account of benefits that the Minister assumed had been conferred upon him as a result of his use of an airplane to which Hollinger International Inc. had access and which the applicant used [3]. 2. ...
TCC
Copthorne Holdings Ltd v. The Queen, 2007 DTC 1230, 2007 TCC 481, aff'd 2011 SCC 63
At paragraph 36, the Court stated: …As long as the transaction has some connection with the common law series, it will, if it was completed in contemplation of the common law series, be included in the series by reason of the deeming effect of subsection 248(10). ...
TCC
Harquail v. The Queen, 99 DTC 1318 (TCC)
Some forty lots were sold between 1973 and 1975, and a few sales took place after that, at unspecified times. [10] In this connection, Arnaud Properties reported profits of $281, $24,974 and $105,410 for 1973, 1974 and 1975, respectively, and declared dividends of $29,300 for 1973 and $36,000 for 1975. [11] Arnaud Properties did nothing other than sell lots; it did not build on the lots. ...
TCC
Granger v. The Queen, 2001 DTC 386 (TCC)
The Appellant testified that there were no horse stables, no country club membership, no tennis courts, no swimming pool extant in connection with the land. ...
TCC
Ross v. The Queen, 2013 DTC 1250 [at at 1400], 2013 TCC 333
The proffered “window dressing” argument is relevant to the Minister’s decision to revoke the registration not to the factual issue of whether misrepresentation has occurred in connection with that fact. ...
TCC
6379249 Canada Inc. v. The Queen, 2015 DTC 1109 [at at 638], 2015 TCC 77
In developing the printer, the appellant set the following specifications: − the printer had to be small and light, the dimensions were to be 1.5” x 1.5” x 10”; − the printer had to deliver a full-sized 8” x 11.5” sheet of copy or graphic; − the printer had to connect to a data source such as cellular phone, PDA or a laptop via the Bluetooth; − the printer had to use wireless technology permitting it to print without the need for a cable connection; − the printer had to be self-contained, meaning that the paper had to be inside the printer on a reel in a very tightly curled compact roll; − the paper cartridge had to consist of 20 sheets of paper; − the printer had to be battery operated and the battery had to function for a full cartridge of paper between recharges. [22] Since the paper in the printer was rolled very tightly, the printer had an anti-curl system designed to ensure that the paper would be flat when it came out of the printer. [23] In 2008, the appellant tested some prototype printers in its laboratory. ...
TCC
Deuce Holdings Ltd. v. R., 97 DTC 921, [1998] 1 CTC 2550 (TCC)
But the same general effect will be had in connection with the retiring allowance when it is ultimately paid out? ...