Search - connection

Instead, the Appellant offered the job of General Manager to an accountant affiliated with its lawyer’s office whose résumé admitted into evidence shows no connection or experience in the insurance industry other than working in an accounting capacity to configure and operate the general ledger and management reporting requirements of her former insurance company employer. [113]    Oddly enough, Ms. ... However, the Treaty requires in paragraph 5 dealing with reinsurance premiums, that: In consideration of the liabilities and obligations ceded to the Reinsurer in connection with the Annuities (the “ Ceded Liabilities ”), as at the Effective Time the Company shall transfer to the Reinsurer assets with a value equal to, and matched with, the Ceded Liabilities as at the Effective Time (the “ Transferred Assets ”) and on that account shall, at the Effective Time, transfer the assets set out on Schedule 5 to this Agreement. [143]    There was no list of the ceded liabilities being the list of transferred annuities attached to the agreement. ...

In the former case, in his analysis of this expression Thurlow, J. stated [see 4.02(2), at 214 (D.T.C. 6183]: (It may not always be easy to decide whether an expense has so arisen but it seems to me that the words “in the course of" in paragraph 11(1)(cb) are not a reference to the time when the expenses are incurred but are used in the sense of “in connection with” or "incidental to" or “arising from" and refers to the process of carrying out or the things which must be undertaken to carry out the issuing or selling or borrowing for or in connection with which the expenses are incurred) In Côte-Reco Inc. ...

The court is only required to consider whether the series was taken into account when the decision was made to undertake the related transaction in the sense that it was done “in relation to” or “because of” the series (Trustco, at para. 26). [47]      Although the “because of” or “in relation to” test does not require a “strong nexus”, it does require more than a “mere possibility” or a connection with “an extreme degree of remoteness” (see MIL (Investments) S.A. v. ... In the end, it will be the “because of” or “in relation to” test that will determine, on a balance of probabilities, whether a related transaction was completed in contemplation of a series of transactions. [15] [66]         It also concluded that subsection 248(10) allows either prospective or retrospective connection of a related transaction to a common law series. [16]   Further, if I find that there was a series of transactions which resulted in a tax benefit, the finding that one transaction in the series was an avoidance transaction will satisfy the requirements of subsection 245(3). [17] [67]         Counsel for the Appellant did not dispute during the hearing that the sale of RAC LP to OMERS Realty Corporation was part of the series of transactions that the parties agreed contained one or more “ avoidance transactions ”. ...

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. ...

WHEREAS the Company carries on a same day transportation and distribution business and is licensed to use certain trademarks in connection therewith;   AND WHEREAS the Owner Operator owns/leases a vehicle [6] (the “Vehicle”) suitable to the business and the provision of services for the Company, and the Owner Operator desires to perform, and the Company desires to engage the Owner Operator to perform, certain distribution and delivery services for the Company;   AND WHEREAS, subject to the prevailing provisions of any applicable Collective Agreement, the Company and the Owner Operator desire to fix and determine between themselves their respective rights and obligations:   NOW THEREFORE in consideration of the mutual covenants and agreements hereinafter contained the parties hereto agree as follows:   1.         ... Uniforms for purchase by the Owner Operator at the Company’s cost price, plus applicable taxes, payable by the Owner Operator on invoice therefore. ii)         When the Company’s trademarks, tradename, logos or decals are displayed or shown on a uniform or the Owner Operator’s motor vehicle, not to place any other name, notice, advertising, decal or painting of any nature or kind whatsoever on the uniform or motor vehicle other than as expressly permitted by the Company which may not be unreasonably and arbitrarily withheld. iii)         The trademark “Dynamex ”, distinctive colour and designs used in connection therewith, are all the property of the Company and their use accrues wholly to the benefit of the Company. ...

Eisbrenner each testified that there was no connection between the cash donation identified in the promotional materials as “ Stage 1 ” and the balance of the steps identified in the promotional materials as “ Stage 2 ”, and that there was no obligation to make a cash donation to be considered as a potential Class A beneficiary of CHT. [41] [36]   Mr.  ... Rosenberg and Marigold recommend thus have no connection with the transactions prices actually charged and received by manufacturers for generic drugs in Canada. ...

Most of the sales were handled by Ken Holloway on a one-on-one basis when people would visit the offices of Thill Inc. in connection with another matter as the business of Thill Inc. included provision of financial advice and preparation of income tax returns. ... Thill, personally, received the sum of $29,894 and $11,600 went to Thill Inc. while another $78,785 was paid in commissions to people in connection with the sale of a variety of partnership units. ...

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. ...

To avoid the tax payable in connection with the unrealized capital gain, they simply had to sell their stake. ... The Company will keep RoundTable informed of all arrangements entered into by its shareholders in connection with the Proposed Transaction and provide adequate documentation in respect thereof.   11 See Authier transcription, Appendix 8, pp. 58–60. 12 See the letter of intent dated January 25, 2002, Appendix 10.   ...

Hupman’s words, had a connection to both the making of the taxable supplies and the making of the exempt transportation service. ... Finally, if the area had a connection to both the taxable supplies and the exempt supplies, meaning that it was intended to be used directly or indirectly for both, then it was treated as a common area. [132] It is the Appellant’s position that the extent to which it acquired, imported or brought into a participating province property or services for consumption, use, or supply in the course of its commercial activities can be determined by taking the total square metres of all areas of the Vessels that were used exclusively in the making of taxable supplies for consideration and dividing this figure by the total of the square metres of all areas of the Vessels that were used exclusively in the making of taxable supplies for consideration and the square metres of all areas of the Vessels that were used exclusively in the making of exempt supplies. [133] Originally, the Appellant had used the following formula: the total square metres of the areas of the Vessels used in making taxable supplies divided by the difference between the total area of the Vessels and the total square meters of the common areas of the Vessels [28]. ...