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Results 11351 - 11360 of 15462 for connection
TCC
Wabush Iron Company Limited v. The Queen, 2009 DTC 814, 2009 TCC 239
The construction and investment disbursements included all costs associated with the acquisition, development and construction of the Wabush Mines, the cost of all replacement property acquired in connection with the Wabush Mines and certain advance minimum royalty payments, as well as required investments in project subsidiaries or parties connected with the Wabush Mines ...
FCTD
Cal Investments Ltd. v. The Queen, 90 DTC 6556, [1990] 2 CTC 418 (FCTD)
In this connection the reader may be reminded that a seal "imports" both consideration and delivery: that is to say, where a contract is under seal it is not necessary to prove either consideration or the delivery of the contract, consideration not being necessary in the case of a contract under seal and delivery being presumed. ...
FCA
The Queen v. Daly, 81 DTC 5197, [1981] CTC 270 (FCA)
In this connection, I refer once again to the respondent’s evidence at trial that no steps were taken to revoke, rescind or waive whatever rights he had under the 1967 contract nor did he ever submit a written resignation. ...
TCC
Transalta Corporation v. The Queen, 2012 DTC 1106 [at at 3044], 2012 TCC 86
In connection with the above issuances of Shares, the Appellant increased its stated capital account in respect of its common shares by the following amounts, which are equal to the fair market value of the issued Shares at the time of issuance with respect to each of the Relevant Taxation Years: Relevant Taxation Year Increase to the Appellant’s Stated Capital as a result of PSOP Share Issuance 2001 $1,827,694 2002 $1,848,755 2003 $1,425,263 2004 $1,112,576 23. ...
TCC
Global Cash Access (Canada) Inc. v. The Queen, 2012 TCC 173, rev'd in part 2013 FCA 269
[83] I would conclude, therefore, that the supply by the Casinos in connection with arranging for the issuance of cheques is excluded as a financial service by virtue of a combination of paragraphs (r.4) and (r.5) ...
TCC
Nguyen v. The Queen, 2011 DTC 1059 [at at 324], 2010 TCC 503
Ultimately, it related only to payment of the lawyer’s and notary’s fees in connection with the estate ...
FCTD
Gulf Canada Ltd. [previously Gulf Oil Canada Ltd.] v. Her Majesty The Queen and Gulf Canada Resources Ltd. [previously Gulf Oil Canada Ltd.] v. Her Majesty The Queen, 90 DTC 6622, [1991] 1 CTC 99 (FCTD), aff'd 93 DTC 6123 (FCA)
"Canadian resource property" is defined in paragraph 66(15)(c) of the Act, as amended by S.C. 1974-75, c. 26, subsection 35(21), as follows: "Canadian resource property" of a taxpayer means any property acquired by him after 1971 that is, (i) any right, licence or privilege to explore for, drill for, or take petroleum, natural gas or other related hydrocarbons in Canada, (ii) any right, licence or privilege to prospect, explore, drill, or mine for, minerals in a mineral resource in Canada, (iii) any oil or gas well situated in Canada, (iv) any rental or royalty computed by reference to the amount or value of production from an oil or gas well, or a mineral resource, situated in Canada, (v) any real property situated in Canada the principal value of which depends upon its mineral resource content (but not including any depreciable property situated on the surface of the property or used or to be used in connection with the extraction or removal of minerals therefrom), or (vi) any right to or interest in any property (other than property of a trust) described in any of subparagraphs (i) to (v) (including a right to receive proceeds of disposition in respect of a disposition thereof); If l comprehend the defendant's argument correctly, the point is that the lease rental payments were not made for the actual carrying out of exploration within the meaning of a Canadian exploration expense, but rather were payments for maintaining or preserving the right to carry out such activities, and therefore fall squarely within the terms of subparagraph 66.2(5)(a)(iii) of the Act. ...
TCC
Garcia v. The Queen, 2007 DTC 1593, 2007 TCC 548 (Informal Procedure)
[46] In Shultz, the taxpayer received, after becoming a Canadian resident, a bonus adjustment in connection with his previous employment in the U.S. ...
FCTD
Buchanan Forest Products Ltd. v. The Queen, 86 DTC 6282, [1986] 2 CTC 7 (FCTD)
(a) To carry on in all and any of their branches the businesses of loggers, pulpwood cutters, lumbermen, lumber merchants and sawmill, planing-mill and pulpmill owners; (b) To buy, sell, prepare for market, manufacture, import, export and deal in pulpwood, sawlogs, timber, piles, poles, lumber and wood of all kinds and generally to carry on the business of lumbering and the lumber trade in all its branches; (c) To carry on the business of general manufacturers and to establish shops and stores, and to purchase, sell and deal in all kinds of goods, wares and merchandise; (d) To carry on the business of loading, unloading or transporting pulpwood, sawlogs, timber, piles, poles and any other goods, chattels or merchandise; (e) To construct roads and ways of every description; (f) To purchase or acquire and to hold and deal with lands and timber limits or licences; (g) To carry on the business of leasing trucks, bulldozers, power shovels and other types of heavy equipment; (h) To conduct and carry on the business of builders and contractors for the purpose of building, erecting, altering, repairing or doing any other work in connection with any and all classes of building and improvements of any kind and nature whatsoever, including the building, rebuilding, alteration, repair or improvement of houses, factories, buildings, works or erections of every kind and description whatsoever and the locating, laying out and construction of roads, avenues, docks, slips, sewers, bridges, wells, walls, canals and power plants and generally all classes of buildings, erections and works, both public and private, or integral parts thereof, and generally to do and perform any and all work as builders and contractors, and with that end in view to solicit, obtain, make, perform and carry out contracts covering the building and contracting business and the work connected therewith; and (i) For the objects aforesaid to acquire and take over as a going concern the partnership business and undertaking heretofore carried on in the said Improvement District of Red Rock and elsewhere in the said District of Thunder Bay by Kenneth Buchanan, John Buchanan, Frank McKenzie Buchanan and William Grenhall Buchanan under the name of Buchanan Brothers. ...
TCC
Caithkin Inc. v. The Queen, 2014 TCC 80, aff'd 2015 FCA 118
Schedule V, Part IV, section 1 reads as follows: A supply of child care services, the primary purpose of which is to provide care and supervision to children 14 years of age or under for periods normally less than 24 hours per day, but not including a supply of a service of supervising an unaccompanied child made by a person in connection with a taxable supply by that person of a passenger transportation service ...