Search - connection

Results 801 - 810 of 3270 for connection
TCC

Maruya v. R., [1997] 3 C.T.C. 2230

There has been difference of opinion on whether the word“ combination” in s. 13(1) requires some “connection” by way of physical relationship or integration or interconnection between farming and the subordinate activity which provides another source of income. Section 3(f) of the Income War Tax Act of 1917, as amended, made reference to “connection” in defining the permissible deductions from income derived from the chief business, trade, profession or occupation of the taxpayer in determining his taxable income. ...
TCC

Denis Beaumier Ltée v. R., [1998] 2 C.T.C. 2155

The trip was a business trip the cost of which was claimed as an expense incurred in connection with the appellant company's business. ... The business trip to the Orient was a trip for which the appellant company signed up for business purposes and it should for the following reasons be considered as an expense incurred in connection with the appellant company's business: (a) it was sponsored by the Association de la construction du Québec; (b) it was specifically organized for member contractors of the Association de la construction du Québec; (c) its purpose was to enable participants to attend conferences offered by various construction associations including the Hong Kong builders association, the Thailand builders association, and the Singapore builders association; (d) The conferences were aimed at providing Canadian contractors with information on various techniques used by contractors in the construction industry in the Orient and on the conditions under which contracts are concluded there, particularly with regard to: construction in wetlands; materials used; contractual obligations of contractors; relations and negotiations between contractors and government organizations; negotiations with unions; etc. ...
TCC

Pai v. M.N.R., 2008 TCC 456

Pai did the necessary paperwork in connection with the services provided by RHS to its customers and this sideline business currently provides about one-third of Yazdani’s annual revenue. ... She saw the advertisement placed by Regions and recognized the name but only in connection with the accounting business that prepared her husband’s tax returns. ... Fawaz blamed CRA for having seized certain documents in connection with the agency investigation concerning the GST fraud of which he was later convicted ...
TCC

Dynamic Industries Ltd. v. The Queen, 2004 TCC 284

Travel which occurs "in the course of employment" has specifically been dealt with by the Courts in connection with employee travel expense deductions set out in paragraph 8(1)(h) of the Act. ... S.I.I.L. would reimburse Dynamic for all travelling and other expenses actually and properly incurred in connection with Martindale's duties. ... Respondent's Argument re: Martindale [141] Counsel referred to Wright, supra. and disagreed that this stood for the proposition that Martindale was travelling "in the course of" or "in connection with" his employment with Dynamic. ...
TCC

Madison Pacific Properties Inc. v. The King, 2023 TCC 180

Examples of a common connection might include “a voting agreement, an agreement to act in concert, or business or family relationships”. [18] A simple common identifying feature without a common connection is not enough. [65] For the purposes of this analysis, it does not matter when the Madison Group and the Vanac Group had the common connection. ... They saw opportunities from working together. [69] The foregoing is not enough for me to conclude that Madison and Vanac had a common connection. ... Heung’s connections to Madison and Vanac are obvious. The following is a summary of the connections of the other three nominees. [113] Mr. ...
TCC

Dr. Mike Orth Inc. v. The Queen, 2013 DTC 1110 [at at 588], 2013 TCC 123 (Informal Procedure)

Olson referred to this work as "general advice" in connection with the business, including employment issues. ... Olson declared, were for advice in connection with "some current and future distribution strategies" for the appellant. ... Olson the fees were for advice "in connection with some current and future distribution strategies" for the appellant and included advice and preparation of documents in connection with the distributions. ...
TCC

Tyoxide Canada Inc. v. The Queen, 93 DTC 1499, [1994] 1 CTC 2569 (TCC)

Maurice further indicated that since 1985 the appellant has benefited from a tax credit under Quebec legislation for the salaries which it pays in connection with scientific research and experimental development. ... Counsel for the appellant referred in this connection to the theory of the separation of the three powers, the executive, the legislative and the judicial powers. ... M further emphasized that the federal government collection business that came through this connection was periodically up for tender, and that business could easily be lost in the contract-tender process. ...
TCC

Motech Molding Inc. v. The Queen, 2012 DTC 1293 [at at 3913], 2012 TCC 351

Byram to claim the capital loss as, in his view, there was a sufficient connection between Mr.  ... Where a loan is made for the purpose of earning income through the payment of dividends, this connection is sufficient to satisfy the purpose requirement of subparagraph 40(2)(g)(ii) ... The payment of the sponsorship fees to Orion has a connection with Phoenix’s stretch wrapping and packaging activities, an industry highly specialized.   37.    ...
TCC

Savard v. The Queen, 2008 TCC 62

Rather, this was a benefit granted in connection with his employment with Industries FDS Inc., which was in fact provided for in his employment contract ...   [19]     The Appellant reviewed the company’s tax history as it related to the fees paid in connection with his case. He explained that the company had been audited previously, as a result of which the principal shareholder, his spouse, had been assessed in connection with the shareholder benefit relating to the payments of the same professional fees, which were owing and paid in connection with the criminal charges against her spouse ...
TCC

Shaver v. The Queen, 2003 DTC 2112, 2004 TCC 10

Analysis Travel expenses [23]     The question raised is whether the travel expenses incurred by the appellant to attend the monthly business seminars may be deducted in their entirety as current business expenses or whether the deduction is limited by the application of subsection 20(10) of the Act. [24]     The respondent obviously does not dispute that the travel expenses were incurred by the appellant in connection with his Amway business. ... In my view, in this case, the trips to the U.S. were made in connection with the business. [36]      Having said this, the court came to the conclusion that the awareness gained by attending the meetings in question was a capital asset, and the deductibility of expenses incurred to attend those meetings was limited by the application of subsection 20(10) of the Act. ... As a result, only the expenses incurred for two conventions were allowed in accordance with subsection 20(10) of the Act. [41]      Furthermore, a distinction is made between training costs and costs incurred in connection with attending a convention in Interpretation Bulletin IT-357R2. ...

Pages