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Results 961 - 970 of 3270 for connection
TCC
Allegro Wireless Canada Inc. v. The Queen, 2021 TCC 27
In particular, the objective was to develop methods to enable more efficient streaming of digital audio, connection-handling mechanisms to translate UDP to TCP and reduce the overhead related to TCP timeouts. [3] [144] Mr. ... Because of the latency of cellular networks, it is not easy to determine whether a connection has timed out. [186] Mr. ... Doctor Penn’s Opinion [191] Doctor Penn explained that in order for the Appellant to keep the connections from timing out, it needed to consider the limited CPU capacities and networking capacities of each of the devices involved. ...
TCC
Filipek v. The Queen, 2008 DTC 4139, 2008 TCC 351
(iv) Factors to consider in determining residency are connections in Canada regarding property, investments, employment, family, business, cultural, social- a non-exhaustive list ... From 1985 to 1992, he was involved in litigation with the Northland Bank, in connection with the financing of this property, resulting ultimately in losing the property. ... [30] With respect to family ties, I conclude that this is not a neutral factor, but shows some degree of ongoing connection to Canada. ...
TCC
Vegh v. The Queen, 2012 DTC 1131 [at at 3160], 2012 TCC 95 (Informal Procedure)
Vegh earned his living and supported his family were carried on in China where he chose to live with little Canadian connection whatsoever ... Vegh ceased to be a resident of Canada when he first left Canada as a single person leaving little behind in Canada with no demonstrated intention to return, and leaving few maintained connections to Canada of a personal, social, or economic nature. ... These do not demonstrate a sufficient connection of Mr. Vegh’s personal status and the general mode of his life to establish that he became a Canadian resident once again. ...
TCC
Corporation A.A.A. S.A. v. MNR, 92 DTC 1805, [1992] 1 CTC 2476 (TCC)
First, the authority must clearly indicate that the corporation is carrying on a business through the agent, and second, the agent must have the power to contract on behalf of the corporation in connection with the business. 4.03.2(3)(g) As to paragraph 253(b) of the Act, which provides that to carry on a business it will suffice to have "offered anything for sale” in Canada through an agent or servant, the appellant alleges that what was offered was Company's shares and that as it was itself an investment company, it was natural to regard this as carrying on a business. ... In this connection, it seems clear that the legislator wishes to give a nonresident corporation disposing of taxable Canadian property two options. ... In this connection, the courts and commentators have many times indicated the conditions that must be met for the payment of a debt to be legally valid. ...
TCC
Spectron Computer Corp. v. MNR, 93 DTC 1473, [1993] 2 CTC 3148 (TCC)
Canada, [1990] 1 C.T.C. 357, 90 D.T.C. 6300 (F.C.T.D.) wherein the taxpayers were operating an independent distributorship of Amway products and in connection therewith attended networking meetings in the United States designed to develop leadership skills germane to the expansion of their business. In the course of his judgment Mackay, J., at pages 366-67 (D.T.C. 6307), noted that if the meetings had attributes pertaining to educational or training sessions involving advanced study or testing, or formal curricula normally associated with training sessions to maintain or upgrade skills or knowledge, the expenses incurred in connection therewith were likely allowable under paragraph 18(1)(a) of the Act. ... This provision permitted deductibility, notwithstanding its capital aspects, of expenses “in attending, in connection with the business, not more than two conventions held during the year by a business or professional organization”. ...
TCC
Safety Boss Ltd. v. The Queen, 2000 DTC 1767 (TCC)
At all relevant times, Miller's duties in connection with the Business included undertaking all strategic planning, direct responsibility for negotiating all contracts with customers and for maintaining good relationships with suppliers, responsibility to ensure that the contracts of the Business were completed to an appropriate standard, responsibility for management of day to day operations for all oilfield firefighting activities, recruitment of all personnel, purchasing of all supplies necessary to carry out contracts, and arranging for all financial aspects pertaining to the Business. 9. ... It was in connection with Mr. Miller's efforts on the Kuwait project. ... In the 1981 Revenue Canada Round Table, the following answer was given in response to a question relating to the reasonableness of salaries and bonuses: In general, the Department will not challenge the reasonableness of salaries and bonuses paid to the principal shareholders-managers of a corporation when (a) the general practice of the corporation is to distribute the profits of the company to its shareholders-managers in the form of bonuses or additional salaries; or (b) the company has adopted a policy of declaring bonuses to the shareholders to remunerate them for the profits the company has earned that are, in fact, attributable to the special know-how, connections, or entrepreneurial skills of the shareholders. [49] Mr. ...
TCC
Comtronic Computer Inc. v. The Queen, 2010 TCC 55
Leung had any legitimate connection to either corporation. [14] From September/October 2003 to September 2004 Comtronic purchase orders placed through Mr. ... Leung had any legitimate connection to that individual. [17] From November 2004 to September 2005 orders by Comtronic through Mr. ... That question does not arise only in connection with strict liability offences, although with the growth in regulations and the multiplication of statutory offences the field of strict liability has proven to be the most fertile for the emergence of this defence. . . . 38 This brief review of the legislation and case law leads to the following conclusion. ...
TCC
Ekamant Canada Inc. v. The Queen, 2010 DTC 1039 [at at 2741], 2009 TCC 408
Sexton J.A. of the Federal Court of Appeal wrote as follows at paragraph 36 of that decision: Based on these cases, I agree with the appellant's submission that simple ownership of a mathematical majority of shares by a random aggregation of shareholders in a widely held corporation with some common identifying feature (e.g. place of residence) but without a common connection does not constitute de jure control as that term has been defined in the case law. I also agree with the appellant's submission that in order for more than one person to be in a position to exercise control it is necessary that there be a sufficient common connection between the individual shareholders. The common connection might include, inter alia, a voting agreement, an agreement to act in concert, or business or family relationships. ...
TCC
May Estate v. MNR, 89 DTC 534, [1989] 2 CTC 2305 (TCC)
BETWEEN PHYLLIS MAY as Grantor AND GERALD MAY, KEITH MAY and JOYCE BOWERMAN as Grantee WHEREAS the parties hereto have reached a settlement and agreed to a consent order in connection with Unified Family Court Action No. 517 of 1984, Judicial Centre of Saskatoon; AND WHEREAS it is a condition of obtaining the consents of Gerald May, Keith May and Joyce Bowerman to the said settlement that they be granted certain rights with respect to certain lands, which said lands shall be ordered to vest in the Grantor as part of this said settlement; AND WHEREAS the Grantor has agreed in consideration of the settlement reached, to convey certain rights in these said lands to the Grantee; NOW THEREFORE it is hereby agreed as follows: Right of First Refusal 1. ... In the event that the Grantor receives a bona fide offer to purchase from a third party, as set out in paragraph 4 hereof, which offer the Grantor is ready, willing and able to accept, and the Grantor does not communicate said offer to the Grantee forthwith prior to accepting said offer or in the event that the Grantor or any person or corporation takes any proceedings to remove the caveat of the Grantee filed to protect their rights hereunder, then this agreement shall be deemed converted into a binding option to purchase agreement as of one day prior to the day on which the Grantor accepts said offer, or proceedings are commenced to remove the said caveat, and on the following terms, which terms shall only bind the parties in such event: OPTION TO PURCHASE (a) In consideration of the settlement arrangement reached in connection with U.F.C. ... (iii) The sale shall be completed 60 days after the date of delivering of the notice given in connection with the exercise of the option, unless by such date the appraisal required by paragraph a(i) hereof shall be incomplete, in which case the said appraisal shall be completed at the earliest reasonable date and the sale shall be completed 60 days thereafter. ...
TCC
Maya Forestales S.A. c. La Reine, 2005 DTC 514, 2005 TCC 66, aff'd 2008 DTC 6100, 2006 FCA 35
Moroever, the object of the solicitation, order or offer for sale need not have any connection with Canadian territory. ... In light of this, I do not see what principle would enable me to limit the scope of the provision. [37] In the case at bar, there is no doubt that the appellant, through a mandatary, offered for sale, in Canada, lots or parts thereof on its plantation in Costa Rica; that it solicited orders for services in connection therewith; and that all of this was reflected in a sale, and then in a contract of mandate to develop the lot sold and in another contract of mandate under which the trees would be cut and the timber would be marketed at a later time. ... They were trying to obtain all the documents needed to do a complete audit of the appellant's activities in connection with soliciting Canadians to invest in its teak-tree plantation in Costa Rica. ...