Search - connection

Yelle, 2010 DTC 5128 [at at 7083], 2010 ABPC 94-- summary under Paragraph 251(1)(c) Summary Under Tax Topics- Income Tax Act- Section 251- Subsection 251(1)- Paragraph 251(1)(c) time of dealing is relevant time The taxpayer, who was a member of a partnership, was accused of tax evasion under s. 239(1)(a) in connection with capital cost allowance claims made by the partnership on software that it had purchased at an allegedly inflated price from a vendor who was alleged not to deal at arm's length with the partnership. ...

Yelle, 2010 DTC 5128 [at at 7083], 2010 ABPC 94-- summary under Paragraph 69(1)(a) Summary Under Tax Topics- Income Tax Act- Section 69- Subsection 69(1)- Paragraph 69(1)(a) The taxpayer, who was a member of a partnership, was accused tax evasion under s. 239(1)(a) in connection with capital cost allowance claims made by the partnership on software that it had purchased at an allegedly inflated price from a vendor who was alleged not to deal at arm's length with the partnership. ...

MNR, 61 DTC 34 (TAB)-- summary under Class 14 Summary Under Tax Topics- Income Tax Regulations- Schedules- Schedule II- Class 14 In connection with a purchase by the taxpayer from its president and general manager of the insurance business previously carried on by him, the taxpayer acquired the exclusive right to use the name of the business for a period of ten years. ...

The Queen, [2002] GSTC 124 (TCC)-- summary under Subsection 169(1) Summary Under Tax Topics- Excise Tax Act- Section 169- Subsection 169(1) white knight costs A Canadian public company ("Nowsco") that was engaged in the provision of oil field services incurred significant fees for services rendered by financial advisors and a law firm in connection with seeking a "white knight" following the commencement of a takeover bid for its shares, as a result of which it was able to secure a higher price for its shares from the original bidder. ...

Commissioners of Customs and Excise, [1992] V.A.T.T.R. 221-- summary under Recipient Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Recipient employer the recipient of criminal counsel services The appellant along with seven individual employees was charged with manslaughter in connection with the sinking of its vessel. ...

The Queen, 97 DTC 517 (TCC)-- summary under Computation of Profit Summary Under Tax Topics- Income Tax Act- Section 9- Computation of Profit cost of shares acquired in consideration for largely worthless loan obligation was nil In connection with the acquisition of the shares of a corporation ("LTM") by another corporation ("HSS") of which the taxpayer was the general manager, the taxpayer used the proceeds of a daylight loan to advance money to LTM, LTM loaned the same sum to its shareholders, the shareholders loaned the same sum to the taxpayer on a non-interest bearing basis with the principal not being due for approximately 100 years, and the taxpayer used the sum to pay off the daylight loan. ...

Expense- Shareholder Assistance The taxpayer paid a fee to a financial advisor, calculated as 0.7% of the market value of its equity and of the amount of its long-term debt net of working capital, in consideration for advice provided in connection with considering alternatives to maximize shareholders' value, with an emphasis on merger possibilities. ...

Repairs or Running Expense In finding that costs incurred by the taxpayers, who in partnership carried on a business of distributing Amway products in Canada, in connection with attending conventions in the U.S., would have been non-deductible in the absence of s. 20(10), MacKay J. stated: "I do not doubt that the plaintiffs believe they acquired awareness of how others had been successful and even techniques useful in motivating others to participate and to succeed in the Amway network. ...

Profit- Commodities, and commodities futures and derivatives large purchase of toilet paper at profitable price The taxpayer, a businessman with many interests (lending money, the film business, and dealing in real property) happened to be in Berlin in connection with those interests and had the opportunity of making a purchase of a very large quantity of toilet paper from a bankrupt German firm for less than 10% of the amount for which he was ultimately able to sell the toilet paper to a British purchaser. ...

McMurtry C.J.O. stated (at p. 5364) that the "teams' connection with non-Ontario venues and the control of these venues is relatively so transitory that they cannot be considered to be fixed places of business". ...