Search - connection

His connections with Ireland are, albeit not short, but essentially of a temporary nature and for a limited purpose. ... Now, consider the Canadian connection. He resided here, I believe, not in dispute, from 1930 to 1973, a period of some 43 years. ... I suggest the evidence is that the only connection Mr Erickson has with Ireland is his presence there. ...

Regardless of any connection there may have been between Mr McGowan’s personal affairs and the affairs of the company or any proposal that might have been made in connection with Mr McGowan’s assessments, I cannot accept that chartered accountants who recognized that Mr McGowan and the McGowan company were two separate legal entities, as evidenced by the fact that they filed a separate tax return for each, could have thought that it was unnecessary to file separate notices of objection if they also intended to dispute the company’s assessments. ...

In my view, while counsel for the appellant points out that the testimony of these parties held up very well and counsel for the appellant also notes that there was not a great deal of cross-examination, the statements made by Mr Cousineau in connection with the partnership sharing issue, and those made by Mr Gauthier in connection with the Pointco matter are at the minimum incomplete and largely inconsistent with the documented record. ...

The rest came from persons whom the appellant knew as the result of his activities in connection with Albill’s business. ... The utilization of knowledge gained in connection with ordinary income earning activities does not change the position. ...

When all the facts revealed in evidence are considered together, it is apparent that in 1977 the appellant’s connection with Canada was tenuous. That connection consisted of only two elements of any consequence at all, namely the children and the contract. ...

His wife was unemployed and had no financial means, and all payments in connection with the King Township house were made by the appellant. ... He severed all connections with the King Township residence so far as his family was concerned. ...

Minister of National Revenue, [1975] C.T.C. 2310, 75 D.T.C. 239 A J Frost: 1 This is an appeal from income tax assessments dated April 13, 1973 in respect of appellant's 1968, 1969, 1970 and 1971 taxation years. 2 By the said assessments, each dated June 26, 1973, the following deductions claimed on account of interest paid on borrowed money were disallowed: 1968 $ 18.50 1969 510.90 1970 548.21 1971 478.95 This disallowance should be considered in connection with the fact that appellant had not reported the following mortgage interest income in his taxable income: 1968 $1,540.00 1969 1,517.00 1970 1,492.00 1971 1,465.00 3 On December 15, 1967 the appellant sold his principal residence in Breslau, Ontario and took back as part of the sale proceeds a mortgage in the amount of $21,000. ...

The closest description of the need for the appellant to have “his hands on the goods” appears to arise in Regulation 5202 under “qualified activities” as.. in connection with manufacturing or processing.. I do not view the term “in connection with” as requiring the direct contact asserted by the Minister in this matter. ... The appellant corporation’s “activities... are performed... in connection with manufacturing and processing..and that “manufacturing and processing” include the subcontract work for purposes of qualifying for the deduction claimed. ...

Submissions In contending that Mr Ciceri was a Canadian resident in the pertinent taxation years, counsel for the appellant referred to Mr Ciceri’s Canadian background viz, his birth, education, parents and marriage, as constituting for Mr Ciceri’s connections and ties with Canada which were never broken. It is the appellant’s submission that it was Mr Ciceri’s intention to return to Canada and that he had made no attempt to break his connections with Canada. ... The connections or the ties which Mr Ciceri may have had in Canada from 1967 to 1975, were purely emotional in nature rather than factual and in my opinion, do not meet the tests established by the courts as to what constitutes residency in Canada for tax purposes. ...

He had to spend more and more time outside that city in connection with the development of the businesses of certain of his other companies whose operations were based in Alberta. ... His presence was required in Winnipeg from time to time in connection with the business of Hauling. ... He does not appear to have used the apartment in connection with visits to his children. ...