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TCC

Exxonmobil Canada Ltd. v. The Queen, 2019 TCC 108

ExxonMobil Canada Hibernia Company Ltd. claimed for income tax purposes, that the following work for RCA resulted in scientific and technological advancements, which was accepted by the Minister for the 2005 taxation year: i)   integration of aquifer data at regional and field scales; ii)   study of the role of intermediate structural blocks in dual fluid separation; iii)   gravity segregation of oil; iv)   integration of RCA prediction as first-order predictor to focus Direct Hydrocarbon Indicator studies; and v)   visualization using Petrel 3D models to evaluate plausible connections and spill/breakover points. 71.   ...
TCC

AE Hospitality Ltd. v. M.N.R., 2019 TCC 116

This Agreement may be assigned by the Company in connection with a merger or sale of all or substantially all of its assets, and in other instances with the Independent Contractor’s consent, which consent shall not be unreasonable withheld or delayed. […] [Emphasis added.] ...
TCC

Stark International Inc. v. The Queen, 2019 TCC 248

Property used to manufacture or process goods to be supplied in connection with the provision of a service, namely through a contract for work and materials, is not viewed as being used directly or indirectly in Canada primarily in the manufacturing or processing of goods for sale, and as such, does not qualify for either the accelerated capital cost allowance or the investment tax credit…. ...
TCC

Indusol Industrial Control Ltd. v. The Queen, 2020 TCC 103

The Minister denied the deduction of the said expenses as well as the investment tax credit (“ ITC ”) of $49,224 claimed in connection with those expenses. [3]   At the hearing, Mr.  ...
TCC

Anderson v. M.N.R., 2021 TCC 28

John, a laptop computer, computer software (including software customized for insurance adjusters), an internet connection, utilities and office supplies. [43] Mr. ...
TCC

Logix Data Products Inc. v. The Queen, 2021 TCC 36

This included a new lattice support, changes to the mounting system and the electrical connection system and increasing the size of the solar shingle. ...
TCC

U.S.M. Canada Ltd. v. R., [1996] 2 CTC 2289, 97 DTC 192

.: 283-5831 Re: Purchase of business and net assets of a division of Emhart Canada Limited Dear Sir, In connection with the subject purchase, we have been advised by our Kitchener District Office that the amount of $3,881,761, included among your 1987 additions to class 29 is, in fact, goodwill. ...
TCC

Fording Coal Limited v. Her Majesty the Queen, [1995] 1 CTC 2734

The particular "seeding transaction" had no purpose other than to avoid taxes and had no connection with commercial reality and therefore the Minister was correct in disallowing the CCEE and CCDE for the years under appeal. ...
TCC

Choptiany v. The King, 2022 TCC 112

It should have been very clear to the parties that I was using the word “involving” in a broad manner comparable to the words “relating to”, “with reference to”, “in connection with”, “in relation to” and “in respect of” discussed in Nowegijick v. ...
TCC

Moss v. R., [1999] 4 CTC 2813, 99 DTC 1229

Signed “Rochelle Moss” Rochelle Moss Signed “Armand Levy” Armand Levy This 24th day of September, 1991, in the City of Winnipeg, Manitoba ^ [45] As a result, information was deliberately provided to the District Registrar which was false in that it indicated that Rochelle Moss and Levy were dealing at arm’s length with one another in connection with the sale of the property and that the sale itself was bona fide and for valuable consideration. ...

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