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TCC

Liang v. The Queen, 2022 TCC 55

The definition requires that statements or representations must be made, at some time, in connection with the property that is offered for sale. If no statements or representations have ever been made in connection with a property, then that property cannot constitute a tax shelter. ... (i) Statements or Representations [22] The existence of statements or representations in connection with a property is a necessary condition for a valid shelter. ...
TCC

Duncan v. The Queen, 2001 DTC 96 (TCC)

Belanger, or otherwise inquire into his ability, his expertise, or his claim to have business connections in Eastern Europe. ... Young took the position that it was the expertise and the connections of Mr. ... Wu: [14]                 In this connection we refer to the decision of this Court in H.M. v. ...
TCC

Desrosiers v. The Queen, 2008 TCC 536 (Informal Procedure)

Desrosiers testified that the lands were used in connection with his hay and grain growing, so I am giving him the benefit of the doubt. ...   [26]          This is the GST on professional services rendered by the attorney in connection with Mr.  ...   [32]          For the same reason as note 30. [33]          For fees paid in connection with a seizure of property used by Mr. ...
TCC

Raby c. La Reine, 2006 TCC 406 (Informal Procedure)

Papion about the possible connection between the investors' software analysis (using the questionnaire that the promoters had invited them to fill out) and the CASA project, Mr. Papion reiterated his finding that there was no such connection, because the CASA project was a software engineering project. ... Le Guerrier raised in connection with the management of the partnership. ...
TCC

Ormiston v. R., [1997] 3 C.T.C. 2884, 97 D.T.C. 1396

In January of 1984, Gordon Denford was encountering financial difficulties in connection with a real estate development. 8. ... Any profits from resale of the lot would belong to Fort Chelsea and would arguably not be subject to any financing arrangements entered into in connection with the project. 9. ... In this connection, it is worth reproducing the first paragraph of this letter. ...
TCC

Abinader c. La Reine, 2008 DTC 4785, 2007 TCC 111

I will come back to these different connections later on in these reasons ...   [50]     The auditor, Jean-Claude Delisle, found a connection with the July 24, 1991, donation. ... In this connection, he cites the Quebec Court of Appeal decision in Légaré v. ...
TCC

McFadyen v. The Queen, docket 97-2037-IT-G

There is a clear connection to Canada and, due to the tax immunity enjoyed in the host country, there is an ability to pay. ... However, the Appellant maintained the Canadian connections with Canada in case he did return. ... The decision seems to concentrate on the point that the connections to the U.S.A. seemed more important than those regarding Canada. ...
TCC

Valente v. The Queen, 2006 DTC 2685, 2006 TCC 145 (Informal Procedure)

All students are given access to a dedicated online connection similar to a "chatroom" for each course so that issues can be discussed among the students and with the tutors. ...
TCC

Michaud v. The Queen, 2014 DTC 1089 [at at 3152], 2014 TCC 83 (Informal Procedure)

  [4]              The Appellant acquired a Free Miner Certificate in March 2000 and began reporting expenses in connection with his mining activities in 2002. ...
TCC

Jennings v. The Queen, 2015 DTC 1117 [at at 743], 2015 TCC 96 (Informal Procedure)

I understand that the appellants tried to avoid having a new application in 2010, but the City required them to go through a new process. [17]         Throughout this whole period, the use of the property did not change. [18]         In my view, the expenditures should be viewed as ordinary expenditures incurred in connection with the day-to-day management of the rental property. ...

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