Search - connection

In connection with the DJ business, Mr. Madlener maintained that it was carried on by his numbered company. ... This was in connection with the sale of Bolt Buddies, the security system business in Door & Jamb. ... It was unclear exactly what this related to, although there was some suggestion it was in connection with the Bed and Breakfast. ...

The Mileage Allowances paid by the Appellant are, however, not reasonable as they were based on the lease payments, including the GST, instead of being based solely on the number of kilometres for which the vehicle was used in connection with or in the course of the Employees' office or employment as required by subparagraphs 6(1)(b)(x) of the Income Tax Act. ... (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,... (vii.1) reasonable allowances for the use of a motor vehicle received by an employee (other than an employee employed in connection with the selling of property or the negotiating of contracts for the employer) from the employer for travelling in the performance of the duties of the office or employment,... 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 (x) where the measurement of the use of the vehicle for the purpose of the allowance is not based solely on the number of kilometres for which the vehicle is used in connection with or in the course of the office or employment,... [9]      The same question posed in the case at bar was faced by Lamarre Proulx, J. of this Court in Tri-Bec Inc. v. ...

Since she estimated the distance between the two locations to be eight kilometres, she simply made the following calculation: 8 km x 2 times/day x 5 days/week x 48 weeks/year = 3,840 km [7]      Since the so-called minimum number of kilometres for personal purposes represented a large percentage of the 18,000 kilometres travelled annually, there was no reason to calculate a reduced benefit under subsection 6(2) of the Income Tax Act. [8]      In actual fact, the benefit can only be reduced under subsection 6(2) where fewer than 1,000 kilometres are travelled per month other than in connection with or in the course of the office or employment and where the following conditions are met:                                       [TRANSLATION] The taxpayer is required by the [Corporation] to use the automobile in connection with or in the course of the office or employment, and 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... [9]      The appellant does not dispute the total distance of 18,000 kilometres travelled by the automobile per year and, until the hearing, did not dispute the figures and calculations used by Ms. ... They were without a doubt travel in connection with or in the course of the office or employment. ... Thibault's work, not only that of his spouse, was performed at the residence office, it cannot be stated that the trips between the residence and the technical office constituted travel solely for personal purposes and that they were not made in connection with or in the course of the office or employment. ...

It confirms that throughout that period the appellant, as an ATS employee, performed his duties in the United States in connection with a contract under which the employer conducted an engineering activity. [10]     At the request of the appellant's agent, counsel for the respondent filed the objection audit report as Exhibit I-1. ... Assuming the other requirements of subsection 122.3(1) are met, the employees of A Ltd. providing the data processing services would qualify for the OETC, since their employment is in connection with a contract under which the specified employer carried on business outside Canada with respect to qualifying activities. [13]     The appellant's agent referred to this Court's decision in Terry Gonsalves v. ... Betteridge in France was in connection with a contract the University had with Semex in respect of a business, if any, it carried on in Canada and not abroad. ...

After an adjournment and some discussion, the parties agreed that for those two years the expenses in connection with the property were respectively $41,776 and $40,749. ... For his part, her husband was able to do much of the work of managing the business aspects of the property and the maintenance and repairs in connection with it. ... This is not, however, a case where it was obvious from the outset that the property could not produce a profit, nor is it a case in which there is any personal element in connection with the acquisition or use of the property. ...

Analysis Since the appellant’s employment was in connection with the selling of property or negotiating of contracts for his employer, paragraph 8(1)(f) of the Income Tax Act, R.S.C. 1952, c. 148 (am. ... That paragraph reads as follows: 8.(1) In computing a taxpayer’s income for a taxation year from an office or employment, there may be deducted such of the following amounts as are wholly applicable to that source or such part of the following amounts as may reasonably be regarded as applicable thereto: (f) where the taxpayer was employed in the year in connection with the selling of property or negotiating of contracts for his employer, and (i) under the contract of employment was required to pay his own expenses, (ii) was ordinarily required to carry on the duties of his employment away from his employer’s place of business, (iii) was remunerated in whole or part by commissions or other similar amounts fixed by reference to the volume of the sales made or the contracts negotiated, and (iv) was not in receipt of an allowance for travelling expenses in respect of the taxation year that was, by virtue of subparagraph 6(1)(b)(v), not included in computing his income, amounts expended by him in the year for the purpose of earning the income from the employment (not exceeding the commissions or other similar amounts fixed as aforesaid received by him in the year) to the extent that such amounts were not (v) outlays, losses or replacements of capital or payments on account of capital, except as described in paragraph (j), or (vi) outlays or expenses that would, by virtue of paragraph 18(1)(1), not be deductible in computing the taxpayer’s income for the year if the employment were a business carried on by him… Subparagraph 6(l)(b)(v) reads as follows: 6.(1) There shall be included in computing the income of a taxpayer for a taxation year as income from an office or employment such of the following amounts as are applicable: (b) all amounts received by him in the year as an allowance for personal or living expenses or as an allowance for any other purpose, except (v) reasonable allowances for travelling expenses received by an employee from his employer in respect of a period when he was employed in connection with the selling of property or negotiating of contracts for his employer, (ix)... for the purposes of subparagraphs (v), (vi) and (vii.l), an allowance received in the year by the taxpayer for use of a motor vehicle in connection with or in the course of his office or employment shall be deemed to be in excess of a reasonable amount (x) where the measurement of the use of the vehicle for the purpose of the allowance is not based solely on the number of kilometres for which the motor vehicle is used in connection with or in the course of his office or employment, or (xi) where the taxpayer both receives an allowance in respect of the use of the motor vehicle in connection with or in the course of his office or employment and is reimbursed in whole or in part for expenses in. respect of the same use.... ...

.: The Appellant appeared not to contest the fact that his 1984, 1985 and 1986 years were reassessed respecting the disallowance of advance royalty claims in connection with Applied Research Limited and the Advanced Reading Course [1] but to make submissions respecting the collecting of monies by the Department of National Revenue. ...

Connection was not sufficient and too remote to justify the deduction. ... Doiron, 2012 FCA 71 (FCA) at paragraph 43, that the onus is on the taxpayer to show the connection between the expenses and the business. ... In my opinion, the connection between the legal expenses incurred and the consulting activities is too remote to enable the appellant to deduct them.   ...

Was the fellowship received in connection with Dr. Ismail’s PhD program in Egypt? ... The offer does not mention any connection to Dr. Ismail’s studies in Egypt and Dr. ... Ismail’s perspective I am also not satisfied there is a sufficient connection. ...

The Appellant claimed the deduction of bad debt expenses totalling $73,409.00 in 1988 in connection with these restaurant ventures. ... In this connection, the Appellant stated that he paid CIBC by way of a bank draft that he gave to the bank’s lawyers. ... Halyk of the firm of Halyk Dovell represented the Appellant in connection with both matters. ...