Search - connection

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.                    ...

The loans chosen were those that had a direct connection with the province: loans secured by land in the participating province; loans, not secured by land, made to residents of the province; and certain loans administered by the entity`s employees in the province. [152]                   Clearly, section 11 of the Old Attribution Regulations (and section 26 of the New Attribution Regulations) is attempting to estimate consumption for entities whose principal business is the lending of money. [153]                   In my view, the foregoing textual, contextual and purposive analysis, particularly the examination of the definition of SLFI in paragraphs 149(1)(a)(i) to (x), of the wording of section 11 of the Old Attribution Regulations and of the structure of Part II of the Attribution Regulations, leads to the conclusion that the words “ loan corporation ” as used in section 11 of the Old Attribution Regulations (and section 26 of the New Attribution Regulations) refer to a corporation whose principal business is the lending of money. [154]                   An entity such as the Appellant is only included in the SAM Rules because its principal business is the lending of money. ... Interest on various instruments   (4)  For the purpose of subsection (2), “gross revenue” does not include interest on bonds, debentures or mortgages, dividends on shares of capital stock, or rentals or royalties from property that is not used in connection with the principal business operations of the financial institution.   ... Interest on various instruments   (4)  For the purpose of subsection (2), gross revenue does not include interest on bonds, debentures or mortgages, dividends on shares of capital stock, or rentals or royalties from property that is not used in connection with the principal business operations of the financial institution.   ...

Walsh suggested that the below-market rents could be attributed to poor management of Wilson and linked this to the family connection between Leadway and Biddington, the property management company owned by the deceased’s son-in-law. ...

The connection that counsel is attempting to establish between the shareholder disputes which took place at various times from 1975 to 1980 is too tenuous and nebulous to be reasonably described as a link between those events and the disposition of the Tri-M shares. ...

The paragraph was held to take into income a material acquisition which conferred an economic benefit, so long as the acquisition did not fall within one of the exceptions, and so long as the acquisition was received in connection with employment. 17        In Phillips v. ...

  [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 ...

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.  ...

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 ...

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.         ...

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). ...