Search - connection

He had no office, no classes, performed no services, and had no connection with the university except that he persisted in his endeavour in that period to have the decision reversed. ...

The partnership transferred to the appellant corporation all of its assets in connection with the carrying on of its business. 4. ...

The continued connection of the appellant with the business was therefore of very great importance, not only to a potential purchaser such as Burke who had no experience in the insurance business, but also to potential purchasers already in the business, such as Whitehead. ...

Minister of National Revenue, [1979] CTC 2277, 79 DTC 284 Delmer E Taylor:—This is an appeal heard at the City of Toronto, Ontario, on February 26,1979 and deals with an income tax assessment in which the Minister of National Revenue assessed to tax in the year 1976 an amount of $17,500 received in connection with the termination of the appellant’s employment. ...

(b) The Vendor shall assume the following costs where applicable: (i) Mortgage insurance fee on NHA mortgage (ii) NHA mortgage application fee (iii) Legal costs and disbursements in connection with the preparation of transfer and mortgage (iv) Costs of survey for loan purposes. ...

Law—Jurisprudence—Comments 4.1 Law The main sections of the new Act involved in the present case are subsection 28(1) and section 248 (definition of farming) which reads as follows: Farming business. (1) For the purpose of computing the income of a taxpayer for a taxation year from a farming business, the income from the business for that year may, if the taxpayer so elects, be computed in accordance with a method (in this section referred to as the “cash” method) whereby the income therefrom for that year shall be deemed to be an amount equal to the aggregate of (a) all amounts that (i) were received in the year, or are deemed by the Act to have been received in the year, in the course of carrying on the business, and (ii) were in payment of or on account of an amount that would if the income from the business were not computed in accordance with the cash method, be included in computing income therefrom for that or any other year, and (b) such amount, if any, as may be specified by the taxpayer in respect of the business in his return of income under this Part for the year, not exceeding the fair market value at the end of the year of livestock (other than animals included in this basic herd within the meaning assigned by section 29) owned by him at that time in connection with the business minus the aggregate of (c) all amounts that (i) were paid in the year, or are deemed by this Act to have been paid in the year, in the course of carrying on the business, and (ii) were in payment of or on account of an amount that would, if the income from the business were not computed in accordance with the cash method, be deductible in computing income therefrom for that or any other year, and (d) the amount, if any, specified by the taxpayer in respect of the business in accordance with paragraph (b) in his return of income under this Part filed for the immediately preceding taxation year; and minus any deductions for the year permitted by paragraphs 20(1)(a) and (b). 248. ...

Subject to the decision to be rendered in connection with the sum of $11,058.77 (see paragraphs 3.9 and 4.2.3) the net profits, according to the income and expenditure account filed as Exhibit 1-2, were $22,000. ...

The discovery of illegal acts (committed before the appellant arrived) with respect to a sum of over $50,000 in connection with a trust account containing funds of longterm employees also caused a stir and led to dissatisfaction with the hospital. 3.7 The appellant took the necessary steps to obtain a grant of $750,000 to renovate the hospital. 3.8 Even though the appellant was criticized by some, his work was nonetheless also appreciated since on April 4, 1974 the hospital’s board of directors recommended an increase in salary, in a letter addressed to the Department of Social Affairs filed as Exhibit A-3. 3.9 According to the appellant, there was nonetheless pressure on the appellant to resign, mostly from representatives of socio-economic groups. 3.10 The appellant was approached early in July 1974 regarding this subject. ...

—where the taxpayer was employed in the year in connection with the selling of property or negotiating of contracts for his employer, and (i) under the contract of employment was required to pay his own expenses, (ii) was ordinarily required to carry on the duties of his employment away from his employer’s place of business, (iii) was remunerated in whole or part by commissions or similar amounts fixed by reference to the volume of sales made or the contracts negotiated, and (iv) was not in receipt of an allowance for travelling expenses in respect of the taxation year that was, by virtue of subparagraph 6(1)(b)(v), not included in computing his income, amounts expended by him in the year for the purpose of earning the income from the employment (not exceeding the commissions or similar amounts fixed as aforesaid received by him in the year) to the extent that such amounts were not (v) outlays, losses or replacements of capital or payments on account of capital, except as described in paragraph (j), or (vi) outlays or expenses that would, by virtue of paragraph 18(1)(l), not be deductible in computing the taxpayer’s income for the year if the employment were a business carried on by him. 8.(2) General limitation. ...

In this connection, the following comment to be found at pp 6 and 597 respectively of the Wallace decision (supra), was cited to the Board: What troubles me is that magnitude of the error made by the appellant in declaring his taxable income. ...