Search - connection
Results 3051 - 3060 of 3282 for connection
TCC
Robert J. McMynn and Joanne J. McMynn v. Her Majesty the Queen, [1995] 1 CTC 2417, 95 DTC 329
., or any affiliate or subsidiary designated by it, whereby it will, because of its knowledge of the property, have the right to act as leasing agent, and when applicable, as sales agent for the limited partnership and to have any listing, whether for lease or sale, in connection therewith, in the event of leasing of available space or any sale of the Swansea Shopping Centre Project comprising the business of the limited partnership and shall be entitled to payment in the amount and on the terms usually paid to independent leasing or sales agents operating in the city of Toronto performing similar functions. 10.01 Each subscribing limited partner shall provide by way of initial capital contribution, for each unit acquired, the sum of $100,000, the sum of $12,500 which was delivered at the time of delivery of the subscription and the balance by cash or certified cheque on or before April 15, 1986. 10.02 Each subscribing limited partner shall further provide by way of capital contribution, for each unit acquired, the further sum of $100,000 such amount to be paid by way of delivery of a promissory note issued in favour of H.L. ... We request that our concerns are passed on as soon as possible to those responsible for the excavation and that Consumers’ Gas be notified so that they can inspect the connection. ...
TCC
Tedco Apparel Management Services Inc. v. Minister of National Revenue, [1991] 2 CTC 2669, 91 DTC 1413
Ted Cohen who personally provided Tangerine Inc. with the services that the appellant presumably agreed to provide; [denied as written: his wife also provided services in this connection (trans., page 31)] (f) during the years at issue, Mr. ... Cohen directly with a car and reimbursed certain expenses incurred by him in connection with his work, such as travel and representation expenses; [denied as written: the said car was used by several persons; further, while some expenses were reimbursed, most were paid by Tedco (Exhibit A-1, page 7)] (i) from May 1, 1983 to April 30, 1985, Mr. ...
TCC
Lance L. And Lucile A. Johnson v. Minister of National Revenue, [1988] 1 CTC 2478, 88 DTC 1334
A 10-inch sewer connection was under construction to Hirst Street at Pym Road to serve future subdivision of District Lot 16, this subject. ... The subject has an actual water connection. An examination of the sales from 1968 indicates a constant and increasing demand for lots in the area of the subject. ...
TCC
Phénix v. R., [1998] 1 CTC 2379, 98 DTC 1524
Electrical cable and connections not in excess of 100 feet from distribution board. ... The amendment stated the following: By this modification the parties agree that Radisson is not a party anymore to the plant agreement and Eldorado hereby acknowledges that as of this date no payments by Rupert are due and that Radisson has no obligations of whatever nature in connection with the plant agreement. ...
TCC
Duguay v. R., [1999] 3 CTC 2432
He was prohibited from acting directly or indirectly as an appraiser, promoter, broker or consultant in connection with gifts of works of art to non-profit organizations, such as charities, and in particular museums and fabriques. ... Demers also made a connection between invoices from the Galerie des Maîtres Anciens and Univers du Rail Inc. ...
TCC
Langlois v. R., [1999] 3 CTC 2589
He was prohibited from acting directly or indirectly as an appraiser, promoter, broker or consultant in connection with gifts of works of art to non-profit organizations, such as charities, museums and fabriques. ... Demers also made a connection between invoices from the Galerie des Maîtres Anciens and Univers du Rail Inc. ...
TCC
Simonetta v. The King, 2023 TCC 54 (Informal Procedure)
He appeared by video connection. To my surprise, and possibly to the surprise of the Simonettas, Mr. ... In Happy Valley Farms, Justice Rouleau enumerated several tests that had been used by the courts to determine whether a gain is of an income or capital nature, as follows: a) the nature of the property sold; b) the length of period of ownership; c) the frequency or number of other similar transactions by the taxpayer; d) work expended on or in connection with the property realized; e) the circumstances that were responsible for the sale of the property; and f) motive or intention. [44] [46] The above list of factors continues to be used to determine “whether a gain realized on a disposition of property is an income gain or a capital gain.” [45] The above factors or tests, which are to be applied by reference to the facts of the particular case, “directly or indirectly lead back to the intention of the taxpayer.” [46] I will now consider the above six factors. (1) Nature of the Property [47] The Property was a large custom-built executive home in an exclusive neighbourhood, [47] with five spacious bedrooms, each with its own ensuite bathroom, a private office with a built-in bookcase, three fireplaces, ten-foot or eleven-foot ceilings, [48] laundry rooms on the main floor and the second floor, a finished basement and a three-car garage. [48] As the Property could have been used by the Vendors as their residence or could have been sold with the expectation of making a profit, the nature of the Property is a neutral factor, rather than a determining factor, in this analysis. (2) Length of Ownership [49] The Vendors closed the purchase of the Lot and the Original Dwelling on September 1, 2010. ...
TCC
McNeilly v. The King, 2024 TCC 162
This is particularly true for tax credits that are tailored to cover expenses incurred in connection with the type of actions or activities that Parliament seeks to promote. Tax credits incentivize activities or actions undertaken by taxpayers by focusing on expenses that they incur in connection therewith. ...
TCC
Beaudry v. The Queen, 2010 DTC 1266 [at at 3853], 2008 TCC 17, aff'd Romar v. The Queen, 2010 DTC 5076 [at 6816], 2009 FCA 48
During the same fiscal year, CMRA issued 18 notes to Coral, denominated in Brazilian currency, in connection with the 40 Coral projects. ... [24] Before CMRA and CMRA 2’s contracts with Coral were signed, the partnerships' promoters did not approach any firms other than Coral in connection with the performance of the work contemplated in the contracts ... The Appellants set up research projects, but the great majority of the deductions that they claim have no connection with that research ...
TCC
GlaxoSmithKline Inc. v. The Queen, 2008 DTC 3957, 2008 TCC 324
Fisk made it clear that the price of the API had no connection to its manufacturing costs or to the costs of the generic products. ... There was no connection whatsoever between the two agreements. The respondent submits that this is further evidence that the two agreements were independent from one another ... Fisk 2002-04-30 1537 1534 ~ 1539 5 Y There is a connection here as all questions relate to the French market and Fournier. 4. ...