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TCC

Holte v. The Queen, docket 2001-973(IT)I (Informal Procedure)

The Appellant also testified that he was required to travel extensively throughout Central and Northern Saskatchewan to meet customers and potential customers in connection with the sale of new and used road building equipment. ...
TCC

Mashford v. The Queen, docket 2002-2803(IT)I (Informal Procedure)

I cite the following: (a)            The Appellant was unaware that Aisco had issued a Supplementary T-4 slip in connection with his 1997 taxation year; (b)            The Appellant retained the services of an accountant to prepare and file his income tax return for the 1997 taxation year. ...
TCC

Renz v. The Queen, docket 2001-1890(IT)I (Informal Procedure)

I also wish to note that the Technical Notes released by the Minister of Finance in October 1998 support the statement that I have made concerning the intent of Parliament in enacting section 118.62 (In this connection see Tab 4 of the Respondent's Record). [13]          The appeal is dismissed. ...
TCC

Bissonnette v. The Queen, docket 2001-3066-IT-I (Informal Procedure)

Bissonnette in connection with his 1999 taxation year. The appeal concerns certain payments that Mr. ...
TCC

Austin v. The Queen, 2010 TCC 452

Austin has retained a law firm in connection with these assessments and that valid appeals have been instituted with respect to them ...
TCC

Wyseman v. M.N.R., 2009 TCC 512

Wyseman was engaged to provide certain specified administrative services in connection with the business in the relevant period ...
TCC

Archibald v. The Queen, 2009 TCC 215 (Informal Procedure)

  [5]      The legal fees were billed by a law firm in connection with advice and preparation of documents in relation to the issuance of securities to investors in a new corporation. ...
TCC

Esesson Canada Inc v. The Queen, 2009 TCC 336

Due to difficulties encountered with telephone connections during the hearing held on March 31, 2009, I ordered the parties to provide written submissions respecting the Applicant’s request for an extension of time for the 2003 taxation year. ...
TCC

Walker v. The Queen, 2009 TCC 362 (Informal Procedure)

  [6]               The relevant provisions of the Act are as follows:   252.1 (2) Accommodation rebate for tour packages-- If (a) a non-resident person is the recipient of a supply made by a registrant of a tour package that includes short-term accommodation or camping accommodation, (b) the tour package is acquired by the person otherwise than for supply in the ordinary course of a business of the person of making such supplies, and (c) the accommodation is made available to a non-resident individual, the Minister shall, subject to subsection (8) and section 252.2, pay a rebate to the person equal to the tax paid by the person in respect of the accommodation. 252.1 (8) Rebate paid by registrant-- If (a) a registrant makes a supply of a tour package that includes short-term accommodation or camping accommodation to a non-resident recipient who either is an individual or is acquiring the tour package for use in the course of a business of the recipient or for supply in the ordinary course of a business of the recipient of making supplies of tour packages, (b) the registrant pays to, or credits in favour of, the recipient an amount on account of a rebate under subsection (2) or (3) to which the recipient would be entitled in respect of the accommodation if the recipient had paid the tax in respect of the supply and had satisfied the conditions of section 252.2, (c) the amount paid or credited is equal to the amount that would be determined in respect of the supply under paragraph (5)(b), and (d) in the case of a rebate under subsection (2), (i) payment of the consideration for the supply is made at a place outside Canada at which the registrant, or an agent of the registrant, is conducting business, or (ii) if the supply of the tour package includes the short-term accommodation or camping accommodation and also includes other property or services (other than meals or property or services that are provided or rendered by the person who provides the accommodation and in connection with it), a deposit of at least 20% of the total consideration for the tour package is paid (A) by the recipient to the registrant at least 14 days before the first day on which any short-term accommodation, or camping accommodation, included in the tour package is made available under the agreement for the supply of the tour package, and (B) by means of a credit card or charge card issued by, or a cheque, draft or other bill of exchange drawn on an account outside Canada with, a non-resident institution that is a bank, cooperative credit society, trust company or similar institution, the registrant may claim a deduction under subsection 234(2) in respect of the amount paid or credited, and the recipient is not entitled to any rebate or to any refund or remission of tax in respect of the accommodation. 234 (2) Deduction for rebate in respect of supplies to non-residents-- Where, in the circumstances described in subsection 252(3), 252.1(8) or 252.4(2) or (4), a registrant pays to, or credits in favour of, a person an amount on account of a rebate referred to therein, the registrant may deduct the amount in determining the net tax of the registrant for (a) the reporting period of the registrant that includes the particular day that is the later of the last day on which any tax to which the rebate relates became payable and the day on which the amount is paid or credited; or (b) any subsequent reporting period of the registrant for which a return is filed within one year after the particular day ...
TCC

McIntyre v. The Queen, 2007 TCC 754 (Informal Procedure)

Loewig proceeded with only one issue, the deductibility of $1,391.00 in legal fees incurred in connection with a court proceeding in which he sought to have stopped the continued deduction of support payments by the Family Responsibility Office ("FRO").   2          The facts are quite straightforward. ...

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