Search - connection

d)     The investor’s agreement to grant OCGC Power of Attorney and to appoint OCGC as his agent and true and lawful attorney for purposes in connection with the S/Y Close Encounters LP.   ... Scace to assess whether the financing transactions with Neptune Marine Resources S.A. in connection with the manufacturing of yachts and the provision of services relating to the yacht chartering/luxury cruise business had, in fact, taken place. ... Justice Woods went on to conclude that the evidence pointed to the entire transactions being a scam, and therefore, without a sufficient connection between a genuine business and the losses claimed, the losses were barred from deductibility. ...

They had connection to the transactions or the arrangements that were in place relative to making sure we were in qualifications for the rules and regulations on the NEWCO structure.  ...

The Queen, [2003] 1 F.C. 447, in which the Court held that “simple ownership of a mathematical majority of shares by a random aggregation of shareholders in a widely held corporation with some common identifying feature (e.g. place of residence) but without a common connection does not constitute de jure control as that term has been defined in the case law” (at para. 36). ...

This test has had ample use in that connection by the Federal Court of Appeal and Tax Court of Canada in numerous cases, i.e., in Cundill, earlier referenced, [15] and in Petro‑Canada v. ...

He met the Appellant in the years 1989/1990 in connection with his dealings with a Category 'G' license issued by the Department of Fisheries and Oceans ("D.F.O. ...

The remaining capital contributed by the partners of US$80,000 (CDN$105,736) was used to pay costs incurred by the Partnership in connection with the issue of 825 units. 25.        ...

Subsection 123(1) of the Act defines a “commercial activity” as follows: “commercial activity” of a person means (a) a business carried on by the person (other than a business carried on without a reasonable expectation of profit by an individual, a personal trust or a partnership, all of the members of which are individuals), except to the extent to which the business involves the making of exempt supplies by the person, (b) an adventure or concern of the person in the nature of trade (other than an adventure or concern engaged in without a reasonable expectation of profit by an individual, a personal trust or a partnership, all of the members of which are individuals), except to the extent to which the adventure or concern involves the making of exempt supplies by the person, and (c) the making of a supply (other than an exempt supply) by the person of real property of the person, including anything done by the person in the course of or in connection with the making of the supply; [14]   Subsection 123(1) of the Act defines “exempt supply” to mean “a supply included in Schedule V” of the Act. ...

Auger, the co-owners’ tax accountant, like his counterpart the co-owners’ tax lawyer from MLT Aikins, appear from the evidence to have been professional, thorough and sound in their advice and their actions, and beyond reproach, in acting for their clients in connection with the structuring and closing of the sale of North Hill Shopping Centre. ...

Boles has had a connection to both dogs and horses. [113] As a teenager in Ottawa, she worked at a horse stable, saved her money, and eventually purchased and showed her own horses. [114] She also purchased and showed various dogs, including several Vizslas. [115] She registered her kennel under the name Amberlight. [116] While being cross‑examined about the sale of one of her horses, in anticipation of her relocation to Vancouver to attend law school, Ms. ...

The appellant recalled he delivered a certified cheque in the sum of $10,000 to a law firm in connection with the purchase of a family residence in October, 1996. ... In 1995, Monga obtained farm labour from Bant Suran and- in 1996- did not recall having any contact with Manjit Rana in connection with the workers supplied by SRC. ... He thought this was strange because she told HRDC and Janet Mah- later- her only work for SRC was in connection with vegetables in Richmond. ...