Search - connection
Results 321 - 330 of 3280 for connection
TCC
Campbell v. R., [1998] 1 CTC 2835, 98 DTC 1339
A Settlement Agreement between the lender and Odessa was entered into on March 5, 1986, the relevant provisions of which were: (a) Odessa would release the lender from any liability in connection with any matter arising out of the property or the legal action between the lender and Teacher’s; (b) The lenders would commence legal proceedings to effect a judicial sale of the property and arrange for the submission of a tender in the amount of $16,100,000. ... By this document, those parties: release and forever discharge The Odessa Partnership and each of the partners, and Odessa-Durbin Developments Ltd. from any and all causes of action, liabilities, claims and demands whatsoever at law or in equity which the undersigned had, or hereafter can, shall or may have for any matter whatsoever arising out of or in connection with the Emerson Centre, the mortgage granted by Crown Trust Company to Odessa-Durbin Developments Ltd., the guarantees given by the partners in connection thereto and all matters in connection with the Emerson Centre and in connection with The Court of Queen’s Bench Action No. 8301- 09434. ...
TCC
Obadia v. R., [1998] 4 CTC 2504, 98 DTC 1578
In her testimony the appellant made a connection between the withdrawals from her personal account on the one hand and deposits in the joint account of the appellant and Mr. ... Obadia in connection with certain assessments. Two American Express bills were paid using money from the appellant’s personal account. ... In this connection, the appellant mentioned that the monthly mortgage payments on the house were about $7,000 and that the mortgage loan was about $700,000. ...
TCC
Ozawagosh v. The Queen, 2013 DTC 1239 [at at 1300], 2013 TCC 311 (Informal Procedure)
The Court further said that an activity that gives rise to income and that is important to the economic, social and cultural fabric of the reserve “is relevant to determining whether a sufficiently close connection exists between the Reserve and the source of the Appellants’ income” ... Normally, regard must be had to the nature of the employment as a whole and the surrounding circumstances to determine what connection, if any, the off-reserve employment has to a reserve ... The evidence does not disclose where, in relation to a reserve, NLS carried on its activities, nor does it show what connection the appellants may have had with NLS in terms of benefit to a reserve ...
TCC
Entré Computer Centers Inc. v. The Queen, 97 DTC 846, [1997] 1 CTC 2291 (TCC)
Franchisee’s purchases of Product from Entré, or from Entré’s parent company IE, as the case may be, will be invoiced to Franchisee on the following basis: (i) The Product invoice will reflect the Product Cost (as hereinbelow defined) of the Product(s) being invoiced; to which will be added (ii) a percentage mark-up applied to the Product Cost (the “License Fee Mark- Up” or “Mark-Up”), determined in accordance with Entré’s Mark-Up Schedule and the policies and procedures pertaining thereto, as such may be established and published from time to time, which Mark-Up shall be deemed and considered a license fee charged for the license granted by the Franchise Agreement to Franchisee to use the Proprietary Marks in connection with Franchisee’s operation of an Entré Computer Center at the Center Location. ... For purposes of clarity it will be recalled that it is couched in the following terms:...which Mark-Up shall be deemed and considered a license fee charged for the license granted by the Franchise Agreement to Franchisee to use the Proprietary Marks in connection with Franchisee’s operation of an Entré Computer Center at the Center Location. [24] There is uncontradicted evidence as to why this deeming clause was inserted into the amendment to the franchise agreement: it was in order to develop a potential line of defence against possible liability under the Robinson Patman Act. ... In the instant case, the evidence discloses no rational way in which the variable mark-up, dependent strictly on monthly purchases by a given franchisee, could be linked to the licence granted to use the franchisor’s Proprietary Marks tn connection with the franchisee’s operation. ...
TCC
Vachon v. The Queen, 2008 DTC 4201, 2007 TCC 641 (Informal Procedure)
the investment income's connection to the reserve (residence, source of income, etc.); 2. ... [45] Lastly, we must determine if the Caisse’s activities have a connection to the reserve. ... None of this creates a strong connection with the reserve. As for the first two arguments, they are benefits for the Indian members of the Caisse populaire. ...
TCC
FP Newspapers Inc. v. The Queen, 2013 TCC 44 (Informal Procedure)
[4] In addition, as per paragraph 29 of the ASF, under the Advisory Services Agreement the Appellant was responsible to pay, without reimbursement by the Partnership, all employment expenses, rent, other office expenses, miscellaneous expenses, and all other costs, expenses, and disbursements incurred in connection with providing the advisory services ... … 141.1 (3) For the purposes of this Part, (a) to the extent that a person does anything (other than make a supply) in connection with the acquisition, establishment, disposition or termination of a commercial activity of the person, the person shall be deemed to have done that thing in the course of commercial activities of the person; and (b) to the extent that a person does anything (other than make a supply) in connection with the acquisition, establishment, disposition or termination of an activity of the person that is not a commercial activity, the person shall be deemed to have done that thing otherwise than in the course of commercial activities ... The sample ruling itself required that connection consistent with the wording of subsection 272.1(2) above ...
TCC
Boivin c. La Reine, 2007 TCC 722 (Informal Procedure)
the investment income's connection to the reserve (residence, source of income, etc.); 2. ... [29] The important question is therefore whether the Caisse’s activities have a connection to the reserve. ... [35] In order for the Appellant’s investment income to be exempt, there would have to be connecting factors and a primary connection to a reserve. ...
TCC
Lavie c. La Reine, 2006 TCC 655
Ouellette said that all the Hells Angels knew that Fred was associated with the Laval gang, which was renamed the "Connection" gang in October 2000. ... Ouellette, by the "Connection" gang, and evidence of this was found during the police search on October 16, 2000. ... Plouffe was arrested in connection with this account, and Mr. Ouellette acknowledged that Mr. ...
TCC
Gros-Louis c. La Reine, 2007 TCC 652 (Informal Procedure)
the investment income's connection to the reserve (residence, source of income, etc.); 2. ... [45] Lastly, we must determine if the Caisse’s activities have a connection to the reserve. ... None of this creates a strong connection with the reserve. As for the first two arguments, they are benefits for the Indian members of the Caisse populaire. ...
TCC
Gros-Louis c. La Reine, 2007 TCC 725
the investment income's connection to the reserve (residence, source of income, etc.); 2. ... [45] Lastly, we must determine if the Caisse's activities have a connection to the reserve. ... None of this creates a close connection with the Reserve. As for the first two arguments, what are actually involved are benefits for the Aboriginal members of the Caisse populaire. ...