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Results 61 - 70 of 3277 for connection
TCC
Mulja v. The Queen, 2005 DTC 256, 2005 TCC 60
The Retiring Allowance payment was paid to the Appellant in connection with the Appellant's termination of his employment with Pratama. ... The Appellant returned to Canada on October 24, 1998. [18] The Appellant maintains that he paid $118,193.00 in taxes to the Government of Indonesia for his 1998 taxation year in respect of the Employment Income and the Retiring Allowance. [19] Counsel for the Respondent does not agree that any of the tax payments that were made to Indonesia were paid in connection with the Retiring Allowance. [20] The Minister of National Revenue (the "Minister") issued a Notice of Assessment (the "Assessment") for the Appellant's 1998 taxation year on October 4, 1999. ... The evidence indicated that this foreign tax credit was allowed in connection with the salary received by the Appellant plus some miscellaneous items. ...
TCC
Purves v. The Queen, 2005 DTC 684, 2005 TCC 290 (Informal Procedure)
Purves to do in connection with its design and manufacturing operations, and it assigned that work to Mr. ... Purves perform those duties in connection with a contract under which Comtech carried on business outside Canada with respect to any engineering activity? ... They import such meanings as "in relation to", 'with reference to" or "in connection with". ...
TCC
Haight-Smith v. The Queen, docket 2001-1195-IT-I (Informal Procedure)
[9] Is the Appellant entitled to claim a deduction for cumulative eligible capital in connection with the trademarks? [10] Is the Appellant entitled to claim a deduction for cumulative eligible capital in connection with the development of secret formulas? [11] Is the Appellant entitled to claim a deduction in connection with the loss of $600,000.00 suffered in the investment in Nigerian Petroleum Corporation? ...
TCC
Gill v. The Queen, 2005 TCC 244 (Informal Procedure)
(e) w here the taxpayer's employer... made an automobile available 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... the taxpayer... for the use of the automobile; 6(2) 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 where A is the lesser of (a) the total number of kilometers 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;... ... " In certain circumstances, this reduced standby charge, which is based on the number of kilometres that the vehicle is driven in connection with the employment as required by the employer, may apply. ... In addition, I do not accept that kilometres driven to and from work are "in connection with employment". ...
TCC
Keith v. The Queen, 2004 TCC 793 (Informal Procedure)
Keith's estimate of his mileage for the business vehicle: Year 1999 2000 2001 Total kilometres 13,382 15,000 16,700 Visiting island customers 2,500 2,500 3,000 Visiting Glasgow golf development 1,700 Travel between office/week day 2,400 2,400 2,400 Weekend 960 960 960 (2 trips a day) Off-island business 7,522 9,140 8,640 [10] The Respondent considered the travel between offices as personal, and also concluded the receipts could not justify the extent of the on- and off-island business travel, in reaching a determination that not all or substantially all the kilometres were in connection with business. ... As a percentage, the business travel represents 80.5%, 88% and 89% of total kilometres travelled. [13] Turning now to the standby charge legislation, the pertinent parts of subsection 6(2) of the Income Tax Act read as follows for the relevant years: 6(2) 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/B × [2% × (C x D) + 2/3 × (E- F)] where A is the lesser of (a) the total 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 primarily in connection with or in the course of the office or employment;... [14] The taxpayer can only claim a reduced standby charge if he is required to use the car in connection with his employment, and all or substantially all of the distance travelled is in connection with his employment. ... Keith's percentages are just short of the 90% mark, but viewing his use of the business vehicle in context of what he did for the company, that is, maintaining that personal contact with suppliers and customers vital to the success of his business, I am satisfied that some minimal commuting travel does not detract from the position that the car was used substantially all in connection with his employment. ...
TCC
Cadieux c. M.R.N., 2004 TCC 92
In connection with paragraph 5(c), she mentioned that someone else normally worked for the Payer, a Mr. ... The Appellant mentioned in connection with paragraph 5(d) that it was difficult to find work in her area of expertise which explained why she was working as a special education teacher. [4] In connection with paragraph 5(f), the Appellant mentioned that her services had been retained on a week by week basis. [5] She accepted paragraphs 5(g) to 5(i). ... In connection with the increase in her hourly pay from $10 to $20, she explained that that was what she had requested from the start and her brother had not agreed, but did so for the last two weeks of the period. [8] In connection with paragraph 5 (n), she said that she did about 90 hours of observation and 50 hours of research at home or the library. [9] In connection with paragraph 5(o), the Appellant mentioned that she used her social psychology training to render the services she provided. [10] In connection with paragraph 5(p), she reiterated what she had already said, that she had asked for $20 an hour and her brother had finally agreed. ...
TCC
Strong v. The Queen, 2004 TCC 297 (Informal Procedure)
(b) all amounts received by the taxpayer in the year as an allowance for personal or living expenses or as an allowance for any other purpose, except and, for the purposes of subparagraphs (v), (vi) and (vii.1), an allowance received in a taxation year by a taxpayer for the use of a motor vehicle in connection with or in the course of the taxpayer's office or employment shall be deemed not to be a reasonable allowance (v) reasonable allowances for travel expenses received by an employee from the employee's employer in respect of a period when the employee was employed in connection with the selling of property or negotiating of contracts for the employee's employer, ... ... [12] Subparagraphs 6(1) (b) (v) and (vii) provide that allowances are to be included in income unless they are "reasonable allowances" received by the employee for travel expenses in connection with the selling of property or negotiating of contracts for the employer. ... The incidental to travel the Appellant is claiming has a more direct connection to his office or employment. ...
TCC
Watt v. R., [1997] 2 CTC 2651
The Appellant has submitted a claim to the Respondent on account of medical expenses with respect to her 1994 taxation year (for medical expenses in connection with the period December 6, 1993- December 5, 1994) in the amount of $3,096.00. 3. ... The difference between the position of the Appellant and the position of the Respondent in connection with the medical expense claim relates solely to the item respecting “travel-use of personal vehicle”: (a) The Appellant has made a medical expense claim of $1,519.00 in connection with this item ($0.31 per kilometre); (b) The Respondent has allowed only $260.00 in connection with this item ($0.05 per kilometre x 5200 kms). 5. ... The amount per kilometer that the Respondent has suggested as being reasonable is $0.05 per kilometer (i.e. 5,200 km x $0.05 = $260.00), being the amount that the Respondent is prepared to allow in connection with “travel- use of personal vehicle”. 7. ...
TCC
Belyea v. R., [1999] 2 CTC 2393, [1999] DTC 1069
Although no precise data were supplied by the Appellant in connection with the use of the boat in 1997, the Appellant stated that he “almost broke even”. ... The Appellant asserted that in connection with the Innovative Industries operation he had been involved in many different endeavours over the years. ... I do not even accept that the Appellant spent the hours that he mentioned in his evidence in connection with this operation. ...
TCC
Anderson v. R., 98 DTC 1190, [1998] 1 CTC 2522 (TCC)
They import such meanings as “in relation to”, “with reference to” or “in connection with”. The phrase “in respect of” is probably the widest of any expression intended to convey some connection between two related subject matters. ... On the facts before me, there is a sufficient connection between the receipt of the money by Mr. ...