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Results 331 - 340 of 3280 for connection
TCC
Bastien v. The Queen, 2007 TCC 642
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. ...
TCC
Bastien c. La Reine, 2007 TCC 645
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. ...
TCC
Seguin v. The Queen, docket 2002-745(IT)I (Informal Procedure)
. ▶ 6(1)(e) ◀ (e) Standby charge for automobile — where the taxpayer's employer or a person related to the employer made an automobile available to the taxpayer, or to a person related to the taxpayer, in the year, the amount, if any, by which (i) an amount that is a reasonable standby charge for the automobile for the total number of days in the year during which it was made so available exceeds (ii) the total of all amounts, each of which is an amount (other than an expense related to the operation of the automobile) paid in the year to the employer or the person related to the employer by the taxpayer or the person related to the taxpayer for the use of the automobile; ▶ 6(1)(e.1) ◀ (e.1) Goods and services tax — the total of all amounts each of which is 7% of the amount, if any, by which (i) an amount (in this paragraph referred to as the "benefit amount") that would be required under paragraph (a) or (e) to be included in computing the taxpayer's income for the year in respect of a supply, other than a zero-rated supply or an exempt supply, (within the meanings assigned by Part IX of the Excise Tax Act) of property or a service if no amount were paid to the employer or to a person related to the employer in respect of the amount that would be so required to be included exceeds (ii) the amount, if any, included in the benefit amount that can reasonably be attributed to tax imposed under an Act of the legislature of a province that is a prescribed tax for the purposes of section 154 of the Excise Tax Act; ▶ 6(1)(k) ◀ (k) Automobile operating expense benefit — where (i) an amount is determined under subparagraph (e)(i) in respect of an automobile in computing the taxpayer's income for the year, (ii) amounts related to the operation (otherwise than in connection with or in the course of the taxpayer's office or employment) of the automobile for the period or periods in the year during which the automobile was made available to the taxpayer or a person related to the taxpayer are paid or payable by the taxpayer's employer or a person related to the taxpayer's employer (each of whom is in this paragraph referred to as the "payor"), and (iii) the total of the amounts so paid or payable is not paid in the year or within 45 days after the end of the year to the payor by the taxpayer or by the person related to the taxpayer, the amount in respect of the operation of the automobile determined by the formula A – B where A is (iv) where the automobile is used primarily in the performance of the duties of the taxpayer's office or employment during the period or periods referred to in subparagraph (ii) and the taxpayer notifies the employer in writing before the end of the year of the taxpayer's intention to have this subparagraph apply, ½ of the amount determined under subparagraph (e)(i) in respect of the automobile in computing the taxpayer's income for the year, and (v) in any other case, the amount equal to the product obtained when the amount prescribed for the year is multiplied by the total number of kilometres that the automobile is driven (otherwise than in connection with or in the course of the taxpayer's office or employment) during the period or periods referred to in subparagraph (ii), and B is the total of all amounts in respect of the operation of the automobile in the year paid in the year or within 45 days after the end of the year to the payor by the taxpayer or by the person related to the taxpayer; and ▶ 6(2) ◀ (2) Reasonable standby charge. For the purposes of paragraph (1)(e), a reasonable standby charge for an automobile for the total number of days (in this subsection referred to as the "total available days") in a taxation year during which the automobile is made available to a taxpayer or to a person related to the taxpayer by the employer of the taxpayer or by a person related to the employer (both of whom are in this subsection referred to as the "employer") shall be deemed to be the amount determined by the formula A x [2% x (C x D) + 2 x (E – F)] B 3 where A is the lesser of (a) the total number of kilometres that the automobile is driven (otherwise than in connection with or in the course of the taxpayer's office or employment) during the total available days, and (b) the value determined for B for the year under this subsection in respect of the standby charge for the automobile during the total available days, except that the amount determined under paragraph (a) shall be deemed to be equal to the amount determined under paragraph (b) unless (c) the taxpayer is required by the employer to use the automobile in connection with or in the course of the office or employment, and (d) all or substantially all of the distance travelled by the automobile in the total available days is in connection with or in the course of the office or employment, B is the product obtained when 1,000 is multiplied by the quotient obtained by dividing the total available days by 30 and, if the quotient so obtained is not a whole number and exceeds one, by rounding it to the nearest whole number or, where that quotient is equidistant from two consecutive whole numbers, by rounding it to the lower of those two numbers; C is the cost of the automobile to the employer where the employer owns the vehicle at any time in the year; D is the number obtained by dividing such of the total available days as are days when the employer owns the automobile by 30 and, if the quotient so obtained is not a whole number and exceeds one, by rounding it to the nearest whole number or, where that quotient is equidistant from two consecutive whole numbers, by rounding it to the lower of those two numbers. ... Second, "all or substantially all" of the distance travelled by the automobile during the time it was made available to the employee must be in connection with or in the course of his or her employment. ...
TCC
Irving Garber Sales Canada Ltd. v. Minister of National Revenue, [1987] 2 CTC 2117, 87 DTC 427
I also represented factories who had coats for sale and I was selling because I had developed a very big connection with American buyers. ... Because they found out that I am capable, that I am trustworthy and that I have connections and I was selling goods to Dallas Texas, to Seattle Washington, to New York, to Chicago, all over. ... This is not a situation where the reality was acquired with funds awaiting use in connection with some other business of the company. ...
TCC
Heather Barnard v. Minister of National Revenue, [1985] 1 CTC 2178, 85 DTC 210
In Oil Investments Ltd v MNR, 3 Tax ABC 141; 50 DTC 479, the Income Tax Appeal Board gave consideration to the meaning of the word “allowances” in subsection 3(4) of the Income War Tax Act which provides that any payment made to any person in connection with any employment or allowances on a per diem or other periodic basis shall, subject to certain specified exemptions, be salary of such person and taxable as income. ... While subparagraph 6(l)(b)(v) speaks of an employee employed in connection with the selling of property or negotiating of contracts for his employer, there can be many taxpayers so employed who are on fixed salaries without commissions. While in the opening words of paragraph 6(l)(f) reference is made to a taxpayer employed in connection with the selling of property or negotiating of contracts for his employer these words relate to commission salesman because they are conjunctively tied in with the words “was remunerated in whole or part by commissions or other similar amounts fixed by reference to the volume of the sales made or the contracts negotiated.” ...
TCC
Crystal Beach Park Limited v. The Queen, 2006 DTC 2845, 2006 TCC 183
Other than this commercial connection between their respective enterprises, they had no dealings with each other. ... " [19] [26] Counsel for the Respondent argued that exactly such a connection existed between Tiburzi and Gelder: "--- they have trusted each other. ... In considering the existence of a "connection" between Tiburzi and Gelder, I am also mindful of the Trust Agreement and the effect of the fiduciary duty it imposed on them. ...
TCC
Jean Lafleur, Michael Polis v. Minister of National Revenue, [1984] CTC 2489, 84 DTC 1478
The respondent disallowed the expense on the ground, inter alia, that the appellant was paid by the school for the said services on an hourly basis, that the work was done in connection with his employment, and that, on submission of supporting documentation, the school reimbursed the appellant for transportation and representation costs paid by him in connection with research work. ... The preparing of a bill or submission shall be done by totalling the DIRECT COSTS incurred in connection with the work or service rendered, and adding thereto a surcharge for GENERAL COSTS. ... In this connection it would appear that, since 1971, sponsored research has been an integral part of the school, while before it was a function of the professors. ...
TCC
Robertson v. The Queen, 2010 DTC 1372 [at at 4457], 2010 TCC 552
Robertson’s fishing activities per se, t he connections to the reserve are manifest. ... Neither was the fact that there was no apparent historical connection of the logging site to life on the reserve. ... It is a source that was always there and its present connections are not trappings. ...
TCC
Royal Bank of Canada v. The King, 2024 TCC 125
Canada, 2002 SCC 28, where the Court turned its attention to the phrase, “in respect of” noting that although it suggests “a broad set of connections,” it is not of “infinite reach” and a “proper approach to statutory interpretation” requires that the entire context be considered. ... The Respondent argues that RBC has not demonstrated that there is a sufficient nexus or connection between the expenses incurred to redeem loyalty reward points and the supply of the Foreign Interchange Service. ... No costs shall be awarded in connection with the matters set out above; and 3. ...
TCC
Lyncorp International Ltd. v. The Queen, 2010 DTC 1351 [at at 4335], 2010 TCC 532, aff'd 2012 DTC 5032 [at 6684], 2011 FCA 352
[27] Over half of the flights involved travel to Campbell River, in connection with C.R. ... [31] Finally, in connection with the C.R. Boatland business, Mr. ... [62] All other flights to Alaska, I conclude were non-drilling related, such as work in connection with the lodge ...