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TCC

9028-0157 Québec Inc. v. The Queen, 2014 TCC 61

Lavoie have no connection with the deposits added to Mr. Lajeunesse’s income ...
TCC

2411-3250 Québec Inc. v. The Queen, 2013 TCC 272

The Queen, 2010 TCC 55, [2010] G.S.T.C. 13, where the suppliers used names and registration numbers belonging to corporations with which they had no connection. ...
TCC

Sugnanam v. The Queen, 2013 TCC 189 (Informal Procedure)

  [25]         Personal and living expenses are defined in section 248 to include:   (a)  the expenses of properties maintained by any person for the use or benefit of the taxpayer or any person connected with the taxpayer by blood relationship, marriage or common-law partnership or adoption, and not maintained in connection with a business carried on for profit or with a reasonable expectation of profit,       ...
FCTD

Axa Canada Inc. v. Canada (National Revenue), 2006 FC 17

We . . . do not see any direct connection with the federal tax existing on certain GST components, and moreover we consider that the expenditure of money was actually made, that the GST remains due on these amounts.  ...
FCTD

Palonek v. Canada (Minister of National Revenue), 2006 FC 494

That is, the report prepared in connection with the Second Level Review specifically notes that neither Mr. ...
FCTD

Abbott Laboratories Ltd. v. Canada (Minister of National Revenue), 2004 FC 140

Le Clair that the law firm of Ogilvy, Renault was now authorized to act on behalf of Abbott in connection with the NAFTA review. [9]                 After reviewing the documents provided on Similac Infant formula (normal and advanced) on July 17, 2001, Ross Le Clair wrote to the exporter pursuant to subsection 42.2(1) of the Act to notify it of CCRA's intention to deny preferential tariff treatment for those two products. [10]            Section 42.2(1) of the Act reads: 42.2 (1) On completion of a verification of origin under paragraph 42.1(1)(a), an officer designated under subsection 42.1(1) shall provide the exporter or producer whose goods are subject to the verification of origin with a statement as to whether the goods are eligible, under the Customs Tariff, for the preferential tariff treatment that was claimed. 42.2(2) Basis of statement (2) A statement referred to in subsection (1) must include any findings of fact or law on which it was based. ...
FCTD

Mustang Engineering and Construction Ltd. v. Canada, docket T-2772-93

I note no other factual details underlying that decision are reported, and with no basis for understanding the decision, I do not find it helpful. [16]      Finally, Mustang relies upon Revenue Canada Ruling 9110.050/93 dated February 10, 1984, in which quarry and gravel production operators were held to be manufacturers or producers who were entitled to the federal tax exemption for equipment under Part XIII of Schedule III of the Act. [17]      In my opinion, the wording of the paragraph 1(e) is plain: the activities must occur exclusively at a mine or quarry, not simply in connection with mining or quarrying operations. ...
FCTD

Ebco Industries Ltd. v. Canada, docket T-2519-90

Individual words have definitions which can be looked up in dictionaries, but they acquire the power to communicate a meaning primarily through their connection with other words as part of a structure of meaning. ...
FCTD

Capital Vision Inc. v. Canada (Minister of National Revenue), docket T-493-00

The applicants submit that this suggests that the requests are made in connection with the Capital Vision Inc. audit and note that there is no other audit in evidence. [62]            In Montreal Aluminium Processing Limited et al. v. ...
FCTD

Pacific Network Services Ltd. v. Canada (Minister of National Revenue), 2002 FCT 1158

The Court found that section 231.2 of the Act, when read in conjunction with Article XXVII of the Canada-United States Tax Convention (1980) and section 3 of the Canada-United States Tax Convention Act, S.C. 1984, c. 20 (which is very similar to section 2 of the Canada-France Income Tax Convention Act, 1976), give the Minister the power to issue a requirement for information sought by U.S. authorities in connection with their own taxation matters. [21]            Joyal J., (as he then was) who rendered the Court's decision, gave the following reasons at pages 181-82: Subsection 231.2(1) authorizes the Minister to serve a Requirement on any person for information or production of documents "for any purpose relating to the administration or enforcement of this Act". ...

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