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Results 51 - 60 of 430 for connection
EC decision

Cadillac Contracting and Developments (Toronto) Limited v. Minister of National Revenue, [1962] CTC 275, 62 DTC 1170

He had, however, in reply to an enquiry, received from the Township Engineer of the Township of North York a letter indicating that the land could not be serviced by draining sewage into a sewer which had been constructed for a housing subdivision south of the land in question, and at that time there was no other convenient sewer connection available. ... In the meantime the town planning consultants on Cadillac’s instructions had prepared three alternative tentative subdivision plans for multiple family development of the whole of the area lying between Dufferin Street and the proposed Spadina Road extension but no application was ever made for approval of any of these plans as the problem of obtaining sewer connections had not been solved. ... At this stage there were still details to be worked out before the subdivision would be approved, correspondence was still going on with respect to the sewer connection and in view of the proposed construction of a new trunk sew er in the vicinity in a matter of two or three years arrangements were made for a temporary connection for the appellant’s subdivision with the sewer of the subdivision south of the property, but the agreement with the township for the construction of streets and sewers and installation of services etc. had not yet been signed nor had the plan been finally approved or registered when, early in July 1955, the appellant received through an agent an offer of $840,000 for the whole of the property. ...
EC decision

National Paving Company Limited v. Minister of National Revenue, [1955] CTC 353, 55 DTC 1226

McLaughlin in the contracting business and is a former shareholder and director of the appellant company but has no connection with the firm of Bowen & McLaughlin. ... The $50,000 was held to protect Bowen & McLaughlin against any contingencies which might ‘‘arise in connection with the sale of the contract covered by the $225,000 consideration.’’ ... McIntyre was a third party having no direct connection with the appellant company or with the partnership of Bowen & McLaughlin. ...
EC decision

Minerals Limited v. Minister of National Revenue, [1957] CTC 64, 57 DTC 1063

(d) To buy, sell and deal in, plant, machinery, implements, equipment, conveniences, provisions and other things capable of being used in connection with operations respecting petroleum or natural gas, or other minerals, and natural products, required by the Company and its workmen, and others employed by the Company, including its patrons and customers.” ... Seventhly—all other property to which the Vendor is entitled in connection with the said business.” ... Now, then, I am correct in this, this was done as a systematic method of by-passing delays in connection with negotiation, or the giving by the farmer of the petroleum and natural gas lease to some major oil company? ...
EC decision

Cumming v. MNR, 67 DTC 5312, [1967] CTC 462 (Ex Ct)

When he was on emergency call duty, if not already at the hospital in connection with other cases, he was usually at his home and it is there that he was called. ... The other car, a 1961 Chevrolet station wagon, was used by the appellant in travelling to and from the hospital, to the bank or to the DARMCO office or elsewhere in connection with his practice and to some extent as well, for purposes not connected with his practice. ... Indeed, though in fact he went nearly every day, he had no occasion to go to the hospital at all in connection with his practice except when there was some service to be rendered to a patient there. ...
EC decision

Nathan Robins v. Minister of National Revenue, [1963] CTC 27, 63 DTC 1012

Robins, Referring to our telephone conversation, I hereby confirm that, in the fall of 1952, you consulted me in connection with a proposed purchase of land by your wife. ... What is the connection between the monies you paid in this connection we are now talking about, in this particular case, and the money spent by your wife? ... As the Canada Evidence Act and the Income Tax Act do not mention any rules of evidence in connection with any proceedings taken under these Acts, there is no doubt that the laws of evidence of the province where the proceedings are taken apply. ...
EC decision

Estate of the Late Wilson Workman Butler v. Minister of National Revenue, [1955] CTC 335, 55 DTC 1211

Butler rendered extensive and extraordinary services to the defendant in connection with its aforesaid claim for damages, both before the Mixed Claims Commission and otherwise. ... The remaining amount of $8,395 was to be held on similar terms in connection with any duty that might be payable to the New York State Tax Commission. ... My dear Amos: In connection with your suggestion that some arrangement might be made for a contingent interest to persons willing to finance you to the extent of $5,000, I wish to state that Mr. ...
EC decision

Doyle v. MNR, 70 DTC 6251, [1970] CTC 365 (Ex.Ct.), briefly aff'd 78 DTC 6027, [1978] CTC 530, 1 S.C.R. 547

Hose as to the mutual understanding that it was paid for his connection, and in face of the circular to the shareholders in which the board described this change as one which was handing over to the company Mr. Hose’s connection. I can see no difficulty in construing the document once one knows what the position was and what his rights under the agreement were, and once one appreciates how his personal connection had been preserved to him by those rights, and how under this agreement that connection (be it remembered valued in fact by two accountants at £30,000) was secured to the company. ... He also in fact made over to the company a valuable connection which was a capital asset. ...
EC decision

Mouton Processors (Canada) Limited v. The Queen, [1968] CTC 490, 68 DTC 5292

In any event, it is clear that there must be a causal connection between the imposition or threat of sanctions and the making of the payments. ... Lazarus Philips, Q.C., or the firm of which he was a partner, was the suppliant’s legal adviser in connection with the matter, and that, subsequently, Mr. ... Silverberg’s only possible responsibility in connection with the matter, as long as Morris was looking after the matter as he in fact always did, was to pass on to Morris any information that might be relevant to the matter. ...
EC decision

Capital Management Limited v. Minister of National Revenue, [1967] CTC 150, 67 DTC 5103

But it is clear from the evidence, without making any distinction between trust and contract, that the agent, the Montreal Trust Company, in connection with those subject mutual funds, received all the purchase monies for unit certificates from each individual subscriber (through the brokers appointed ‘by the manager) for such unit certificates, in a fiduciary character as agent, and that the manager, the appellant, had no beneficial interest in any such unit certificates, evidencing ownership of the investments or in the investments themselves or in the investment portfolio held by the Montreal Trust Company. ...
EC decision

David Walfish v. Minister of National Revenue, [1964] CTC 190, 64 DTC 5121

In this business, the appellant is a silent partner and the business is that of a mortgage broker and the appellant receives as his share of the profits a part of the finder’s fees paid in connection with the placing of the mortgages by this company. ...

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