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Results 3261 - 3270 of 3282 for connection
TCC

Bernier v. M.N.R., 2011 TCC 99

On the other hand, it has been held that the following were not bound by a contract of employment: a newspaper vendor not required to follow any schedule, a market porter working at hours of his own choosing, an “adviser” who does not have to adhere to a schedule in contacting his connections for the benefit of a business. ...
TCC

Hammill v. The Queen, 2004 TCC 595

There was no connection. All other entities were connected. Patrick Cox at International was separate from Premier. ...
TCC

Johnson v. M.N.R., 2018 TCC 201

In one of the consultation papers, we find this interesting analysis: The actual history of the adversarial system reveals that the connection between adversarial processes and civil disputes is not as intimate or long-standing as some suppose. ...
TCC

Vocan Health Assessors Inc. v. The Queen, 2021 TCC 49

The difficulty with that is even if assessors spent time in Vocan’s facility on preparatory activities in connection with preparing Reports, it is only the predominant part of the service- the assessment conducted off-site- that is to be considered in making the determination as to whether the supply constituted an institutional health service. ...
TCC

Miksa Marton v. Minister of National Revenue, [1988] 1 CTC 2098, 88 DTC 1047

By letter dated July 28, 1987 received from counsel for Dualflex, the Court has been advised that for the reasons therein outlined, this is being dealt with and litigated separately in connection with the 1984 taxation year. ...
TCC

Black v. The King, 2024 TCC 96

Do all things as directed by the Committee in connection with the granting, vesting or termination of Rights in accordance with the Plan iii. ...
TCC

Garber v. The Queen, 2014 DTC 1045 [at at 2812], 2014 TCC 1

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. ...
TCC

Univar Canada Ltd. v. The Queen, 2005 DTC 1478, 2005 TCC 723

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.  ...
TCC

Bioartificial gel technologies (Bagtech) inc. v. The Queen, 2013 DTC 1048 [at at 228], 2012 TCC 120, aff'd 2013 FCA 164 supra.

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). ...
TCC

Alberta Printed Circuits Ltd. v. The Queen, 2011 DTC 1177 [at at 967], 2011 TCC 232

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. ...

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