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Results 51 - 60 of 142 for connection
Decision summary
Toronto Blue Jays Baseball Club v. Minister of Finance (Ontario), 2005 DTC 5360 (Ont. CA) -- summary under Permanent Establishment
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". ...
Decision summary
Clark v. Oceanic Contractors Inc., [1982] BTC 417, [1983] 1 All E.R. 133 (HL) -- summary under Paragraph 153(1)(a)
., [1982] BTC 417, [1983] 1 All E.R. 133 (HL)-- summary under Paragraph 153(1)(a) Summary Under Tax Topics- Income Tax Act- Section 153- Subsection 153(1)- Paragraph 153(1)(a) carrying on trade was sufficient connection to jurisdiction nS.204(1) of the Income and Corporation Taxes Act 1970 stated baldly that "income tax shall... be deducted or repaid by the person making payment" without (like s. 153(1) of the Canadian Act) stating explicitly that the payor, to be subject to this withholding obligation, must be a resident of or carrying on business in the jurisdiction. ...
Decision summary
Canadian Pacific Ltd. v. Telesat Canada (1982), 133 DLR (3d) 321 (Ont CA) -- summary under Section 96
Telesat Canada (1982), 133 DLR (3d) 321 (Ont CA)-- summary under Section 96 Summary Under Tax Topics- Income Tax Act- Section 96 An agreement between Telesat Canada and the nine principal Canadian telephone companies setting up the Trans-Canada Telephone System did not create a business, the profits from which were shared by the parties but instead provided for the interprovincial connection of the parties' individual telecommunication signals and for a complicated method of revenue settlement, whereby certain revenues received from the operation of the system were attributed to each party in order that it could receive a return on its investment for its particular part in the transmission of telecommunications. ...
Decision summary
Burrard Dry Dock Co. Ltd. v. MNR, 75 DTC 22, [1975] CTC 2011 (T.R.B.) -- summary under Paragraph 20(1)(e)
Flanigan held that the accounting, legal and investment advisory fees incurred in connection with this reorganization all were deductible under s. 11(1)(cb)(i) and noted that it was not necessary for the issuance of the shares to have resulted in the raising of fresh capital. ...
Decision summary
Felty v. Ernst & Young LLP, 2015 BCCA 445 -- summary under Agency
Ernst & Young LLP, 2015 BCCA 445-- summary under Agency Summary Under Tax Topics- General Concepts- Agency presumption that law firm agreement binds client The appellant’s B.C. law firm retained Ernst & Young to provide her with U.S. tax advice in connection with negotiating a separation agreement with her husband. ...
Decision summary
Serres Toundra Inc. v. Agence du revenu du Québec, 2023 QCCQ 10441 -- summary under Paragraph (a)
Agence du revenu du Québec, 2023 QCCQ 10441-- summary under Paragraph (a) Summary Under Tax Topics- Income Tax Act- Section 125.1- Subsection 125.1(3)- Manufacturing or Processing- Paragraph (a) greenhouse cucumber operation was farming The Quebec manufacturing and processing credits claimed by Serres Toundra in connection with equipment acquired for use by it in its greenhouse cucumber-growing operation turned on whether such equipment was Class 29 property. ...
Decision summary
Enterprise Foundry Co. Ltd. v. MNR, 59 DTC 318, 22 Tax ABC 137 -- summary under Paragraph 20(1)(e)
Boisvert drew a distinction between the legal and other expenses incurred in connection with issuing the shares and issuing the supplementary letters patent, and found that the latter were not deductible under s. 11(1)(cb)(i). ...
Decision summary
Hogan v. MNR, 56 DTC 183, 15 Tax ABC 1 -- summary under Subparagraph 20(1)(p)(i)
Fisher accepted the determination made by the taxpayer of a bad debt allowance in connection with the transfer of his retail fur business to a corporation controlled by him. ...
Decision summary
BJ Services Co. Canada v. The Queen, [2002] GSTC 124 (TCC) -- summary under Subsection 141.01(2)
The Queen, [2002] GSTC 124 (TCC)-- summary under Subsection 141.01(2) Summary Under Tax Topics- Excise Tax Act- Section 141.01- Subsection 141.01(2) s. 141.01 was apportionment provision not applying where registrant only making taxable supplies 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. ...
Decision summary
Holt v. Holt, [1990] 1 WLR 1250 (TCC) -- summary under Shares
In connection with matrimonial litigation, the Class A share of the appellant was found to have a fair value of $150,000 rather than the $10,000 figure advanced by the appellant, in light of its entitlement to 1/2 the net property on a winding-up and in light of the entitlement of a holder of that share to hire himself as a manager of the farm and pay himself reasonable remuneration for its services, without fear of being dismissed and without the obligation to consult or take instructions from anyone. ...