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Results 811 - 820 of 3270 for connection
TCC

Yoon v. The Queen, 2005 DTC 1109, 2005 TCC 366

Also her social, cultural and religious connections in Koreawere much more extensive than those in Canada. ... The centre of vital interests test requires an examination of the taxpayer's connections to each country in that specific year. ... The court in Hertel (supra) did not place great weight on this intention despite the many connections the taxpayer had in Canada. ...
TCC

Arbeau v. The Queen, 2010 DTC 1203 [at at 3526], 2010 TCC 307 (Informal Procedure)

There were also some connections. Minor quantities of scrap metal were acquired from the salvage operations. ... There was no functional connection between the two activities- no interconnection, no interdependence, and no interlacing. ... The Appellant claimed that the cable connection was required to test TVs after they had been repaired. ...
TCC

Pioneer Designs Corp. v. MNR, 91 DTC 293, [1990] 2 CTC 2446 (TCC)

Also, the understanding was clear that whatever charges come from each of the directors in connection with the specific work of a project they are to be reasonable and competitive. ... This financial success can only be explained, on the facts of the present case, by the good work, connections and entrepreneurial skills of the five directors. ... In this connection, the approach adopted in the present case appears to me to be in line with the decision of Goetz, J. of this Court in the Earlscourt Sheet Metal Mechanical Ltd. v. ...
TCC

PDM Royalties Limited Partnership v. The Queen, 2013 TCC 270

Pizza Delight Corporation Ltd. and its subsidiaries (the “Company”) owned the trademarks, trade names, operating procedures and systems, other intellectual property and proprietary rights, and all goodwill used in connection with the restaurants and its franchisees (collectively, the “PDM Rights”). [5]              The Appellant was formed under the laws of the province of New Brunswick and its general partners are PDM Restaurants GP Incorporated (“PDM GP”) and the Company. ... The financing expenses were defined as certain fees and other expenses which were incurred in connection with the financing transactions. [12]         Mr. ... The Fund declared that it intended to qualify as a mutual fund trust and some of its activities, as listed in the prospectus, were: investing in securities, holding cash and short-term government debt, paying amounts payable by the Fund in connection with the redemption of any Units and making distributions to Unitholders, issuing Units for cash; issuing debt securities, purchasing securities, etc. ...
TCC

Morin v. The Queen, docket 95-650-IT-G

Charron (Exhibit I-1) in connection with the notarial contract of June 2, 1986. ... The following is a passage from his testimony in this connection: [TRANSLATION] 129. ... L'Ecuyer in connection with the transaction which is at issue in this Court. [21] The information obtained by Mr. ...
TCC

Hyswick v. M.N.R., docket 2002-721(EI)

Hyswick testified he paid his wife a salary of $1,000 per month to assist him in carrying on the home-inspection referral business as well as for performing research in connection with his duties for the City by checking for zoning infractions or lack of a proper building permit in respect of a particular property. ... He used his own cell phone in connection with both activities. He used his own vehicle for Housemaster business and, even though the City supplied him with a vehicle to be used in connection with his enforcement duties, there were instances when he chose to use his personal vehicle so as to be less obtrusive in the course of conducting an investigation. ... Certain forms had to be used and the opening of a file- in connection with an investigation- had to be logged into the City database. ...
TCC

Morris v. The Queen, docket 97-2-IT-G

The Appellant also made the following remarks in connection with the payment for his services: MR. ... In this connection, the following excerpt from the transcript is of some interest: MR. ... In this connection, he referred to the case E. Winemaker v. Canada, [1995] 2 C.T.C. 2992 and 96 DTC 6040. ...
TCC

Discovery Research Systems Limited v. Her Majesty the Queen, [1994] 1 CTC 2473, 94 DTC 1510

These steps had been easily accomplished on a day-to-day basis because of their close proximity and connection. ... It had, on previous occasions given the accommodation to the individual principals of the actual business connection.... ... She had a close connection with the directors of each company and knew of the debtor's ability to repay the loans. ...
TCC

Morin v. R., [1998] 3 CTC 2627, 98 DTC 1434

Charron (Exhibit 1-1) in connection with the notarial contract of June 2, 1986. ... The following is a passage from his testimony in this connection: [TRANSLATION] 129 Q. ... L’Ecuyer in connection with the transaction which is at issue in this Court. ...
TCC

Morris v. R., [1999] 2 CTC 2732, 99 DTC 831

The Appellant also made the following remarks in connection with the payment for his services: MR. ... In this connection, the following excerpt from the transcript is of some interest: MR. ... In this connection, he referred to the case Winemaker v. R., [1995] 2 C.T.C. 2992 (T.C.C.); (1995), 96 D.T.C. 6040 (Fed. ...

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