Search - connection

It is your understanding that a recontribution to an existing arrangement after December 31, 1987 would be deemed to be property held in connection with a statutory arrangement.  ...

In the case of principal shareholder-managers of a corporation, the Department generally will not consider their remuneration excessive in the following circumstances:  the corporation's normal practice is to distribute its profits to these individuals in the form of bonuses or additional salary, or the corporation has a policy of declaring bonuses to the shareholder- managers for corporate profits stemming from special knowledge, skills ar connections, etc. of that person.  ...

The Memorandum to you from Calgary District Office dated March 22, 1990 that you forwarded to us in connection with this matter makes reference to "novation". ...

Co. in connection with any business carried on by it in Canada. 3.      ...

Our Comments Subsection 28(1.1) defines, for purposes of subsection 28(1), inventory owned in connection with a farming business, as "property that would have been included as inventory of the business if the income from the business had not been computed in accordance with the cash method, and includes livestock but does not include animals included in a taxpayer's basic herd (within the meaning assigned by section 29). ...

" The court also held at page 1142 that:      "Having regard to the business carried on by a non-resident insurer, that is, the business of insurance, the definition of "Canadian reserve liabilities" is broad enough to include the liabilities and reserves reported to the relevant authority under the relevant provisions of the Insurance Act which have a connection, directly or indirectly, with the insurer's insurance policies in Canada. ...

With respect to the statutory authority for reassessing XXXXXXXXXX taxation years beyond the normal reassessment period, the provisions of subparagraph 152(4)(b)(iii) will extend the normal reassessment period for a particular taxation year where it can be established that there is a causal connection between the amount of the adjustment for that year and a transaction with a non-resident person with whom the taxpayer is not dealing at arm's length (i.e., the reassessment can reasonably be regarded as relating to the transaction described in subparagraph 152(4)(b)(iii) as required by subsection 152(4.01)). ... Since the application of subsection 75(2) to the dividend income earned by the trust is a direct result of the conditions under which the XXXXXXXXXX shares were transferred to the trust, it is our view that the causal connection required by subsection 152(4.01) has been established and that XXXXXXXXXX income tax returns can be reassessed within the timeframe specified in paragraph 152(4)(b) to include the income attributed to him under subsection 75(2) as a result of his transfer of the XXXXXXXXXX shares to the trust. ...

In connection with the Borrowing, Canco provided an unconditional guarantee (the "Loan Guarantee") secured by, inter alia, Canco's shares in Forco. ... Canco guaranteed Forco's obligations (the "Contract Guarantees", together with the Loan Guarantee being the "Guarantees") in connection with these Contracts as well. 5. ...

Thus, the connection between the employment and the land upon which the employer is located is not as strong in the present situation as it was in Amos or Boubard. ... In our view, the fact that the land XXXXXXXXXX should not be given significant weight, as there appears to be no connection between XXXXXXXXXX and the present employment opportunities at XXXXXXXXXX. ...

They import such meanings as "in relation to", "with reference to" or "in connection with". The phrase "in respect of" is probably the widest of any expression of any expression intended to convey some connection between two related subject matters. ...