Search - connection

Results 941 - 950 of 3270 for connection
TCC

Donald v. R., [1999] 1 CTC 2025

Furthermore nothing in the language of the document limits the deduction of accounting costs incurred by the Appellant in connection with the enforcement of her children’s right to support by their father. ...
TCC

Marquis v. R., [1999] 1 CTC 2653

There was no direct connection between the guarantee and the acquisition of shares. ...
TCC

Ouzilleau v. R., [1999] 1 CTC 2701

(/), (/) and (/) and subsection 8(2) of the Act read as fol- lows: (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 the taxpayer’s employer, and (1) under the contract of employment was required to pay the taxpayer’s Own expenses, (ii) was ordinarily required to carry on the duties of the employment away from the employer’s place of business, (111) 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 travel expenses in respect of the taxation year that was, by virtue of subparagraph 6(1)(b)(v), not included in computing the taxpayer’s income, amounts expended by the taxpayer in the year for the purpose of earning the income from the employment (not exceeding the commissions or other similar amounts referred to in subparagraph (iii) and received by the taxpayer in the year) to the extent that those amounts were not (v) outlays, losses or replacements of capital or payments on account of capital, except as described in paragraph (/), (vi) outlays or expenses that would, by virtue of paragraph 18(!) ...
TCC

Rowe v. R., [1998] 4 CTC 2859

But where there is credible evidence, as there is here, of actual use and enjoyment by the taxpayer of the contiguous land in connection with her house, and such use and enjoyment is not exaggerated or unnatural sort, a great deal of weight must be attached to it in assessing whether such use can be reasonably regarded as contributing to the taxpayer’s use and enjoyment of his residence. ...
TCC

G.A. Panz v. M.N.R., [1989] 2 CTC 2415

On this aspect, I find the circumstances of this appeal to be akin to those of the Cybulski case, supra, where the Associate Chief Judge of this Court says at page 2184 (D.T.C. 1535): I am satisfied that reasonable grounds existed for the appellant's belief that he had severed his connection with the Company as director and secretary-treasurer and concomitantly his responsibility for it when he placed his resignation in the hands of the Company's president and it was accepted by him. ...
TCC

Leduc (J.) v. M.N.R., [1990] 1 CTC 2559

It was thus the majority shareholder who unilaterally decided what the nature of the expenses and their quantum were at the time, in connection with general negotiations for the sale of the shares and termination of relations between the parties. ...
TCC

Bruce Wierbicki v. Her Majesty the Queen, [1997] 1 CTC 2275 (Informal Procedure)

I have no difficulty in accepting that the appellant and his family have lost substantial amounts of money in connection with the ill-fated flower business in which his company engaged. ...
TCC

Knights of Columbus v. The Queen, 2008 DTC 3648, 2008 TCC 307

His office bore no indication of any connection to the Knights of Columbus, and no one from the Knights of Columbus had access to his office. ... There are no signs to indicate the General Agent’s house has any connection to the Knights of Columbus. ... This is a broader inquiry than just looking at the Field Agent’s activities in connection with the Temporary Insurance Agreement. ...
TCC

Sutcliffe v. The Queen, 2006 DTC 2076, 2005 TCC 812

The position is based on a contextual interpretation of subparagraph 115(1)(a)(i) of the Act and Article XV of the Convention, taking into account the fact that domestic flights have a substantial connection to Canada. ... Canadian Association of Internet Providers, [2004] 2 S.C.R. 427 (" SOCAN "). [113] In that decision, the Court applied a rule of interpretation referred to as the "real and substantial connection" test. ... The application of the "real and substantial connection" test in the manner suggested by the respondent would have the effect of expanding the scope of subparagraph 115(1)(a)(i). ...
TCC

Laplante v. The Queen, 96 DTC 1196, [1995] 1 CTC 2647 (TCC)

:—The appellant appeals the reassessments in connection with his 1985, 1986, 1988 and 1989 taxation years. ... The first being where Courts insist on an immediate and direct connection of expense to income. ... The direct connection between the two in most instances was vague. Mr. ...

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