Search - connection
Results 11651 - 11660 of 15462 for connection
TCC
Thistle v. The Queen, 2015 TCC 149
Fitzgerald had expressed concern about claims by individuals who had purchased memberships in the RV park, and he had stated that he did not want any connection with Enterprises. ... However, the connection between obtaining financial statements and discovering either financial difficulty or a failure to remit is a tenuous one, particularly since a private corporation such as Enterprises is not required to have audited financial statements [93] and unaudited financial statements can be manipulated by the person providing the information on which the statements are based. [106] I am unable to conclude that the Appellant’s failure to obtain financial statements of Enterprises indicates that he ought to have known that Enterprises was in financial difficulty when all of the other objective circumstances at the time suggested otherwise. ...
FCTD
Bear v. Canada (Attorney General), 2001 FCT 1192
They import such meanings as "in relation to", "with reference to" or "in connection with". The phrase "in respect of" is probably the widest of any expression intended to convey some connection between two related subject matters. [...] ...
FCTD
Ugro v. Canada (National Revenue), 2009 FC 826
Gibson's decision is not reviewable. 23 There must be at least some causal connection between the mental distress and an inability to act ... The Applicant also notes that there is a casual connection between the mental distress endured by him and his wife and their financial affairs: Dort. ...
FCTD
Humby v. Canada, 2013 FC 1136
On this point, Pauline Butler, now retired from the High Sheriff’s Office and the key connection between CRA and the High Sheriff, also testified. ... [151] Given the findings above, I do not have to deal with the defence asserted in respect to subsection 5(6) of the Newfoundland and Labrador Proceedings Against the Crown Act, RSNL 1990, c P-26. 5. (6) Proceedings do not lie against the Crown under this Act in respect of a thing done or omitted to be done by a person while discharging or purporting to discharge (a) responsibilities of a judicial nature vested in him or her; or (b) responsibilities that the person has in connection with the execution of judicial process. [152] I have doubts that in the face of paragraph 3(5)(f) of the Judgment Enforcement Act the Sheriff is then entitled to claim immunity under the Proceedings Against the Crown Act ...
SCC
Comité paritaire de l'industrie de la chemise v. Potash; Comité paritaire de l'industrie de la chemise v. Sélection Milton, [1994] 2 SCR 406
Southam Inc. is not, unlike a search that may lead to complaints of a penal or criminal nature, applicable to an administrative inspection; (2)different rules should apply to determine whether a search or seizure made in connection with an inspection pursuant to the ACAD is unreasonable; and (3)the absence of a warrant does not make the inspectors' requests unreasonable, even though a refusal is subject to a fine (s. 33 ACAD). ... Dyment, [1988] 2 S.C.R. 417, La Forest J. stated (at p. 431): It should be observed, however, that s. 8 of the Charter does not protect only against searches, or against seizures made in connection with searches. ...
TCC
MacDonald v. The Queen, 2017 TCC 157, rev'd 2018 FCA 128, which was aff'd in turn by 2020 SCC 6
The link in quantum and timing is very important because it locks in either a gain or a price. [87] The Appellant cited Echo Bay Mines Ltd v Canada (TD), [1992] 3 FC 707, 92 DTC 6437 [Echo Bay], Placer Dome, supra, and Salada Foods Ltd v The Queen, [1974] CTC 201 (FCTD), 74 DTC 6171 (FCTD) [Salada Foods], as authorities that confirmed the requirement of an extremely close link between the purported hedge and the underlying asset or transaction in order to support a finding of a hedge for income tax purposes. [88] More specifically, in Echo Bay, supra, the Federal Court of Appeal concluded that there was a sufficient inter-connection and integration with the taxpayer’s business, i.e. the production of silver, such that the gain from the closing out of the forward sales contract was considered income from that business. ... I cannot find any connection between the amount borrowed under the Loan and the entering into, and the settlement of, the Forward Contract. [107] In the present case, there is no particular transaction that occurred around the time Mr. ...
TCC
Aquilini (Estate) v. The Queen, 2019 TCC 132
The evidence is that Francesco executed a guarantee in favour of the vendor in connection with the acquisition of the Vancouver Canucks’ operations and there is further evidence that as between the brothers, any guarantees given by any brother would be the responsibility of all three. ... I note that since I found the predominant or principal purpose of the allocation agreement to be a reduction in tax, the Appellants’ arguments that I should distinguish the cases the Respondent relied upon in connection with subsection 103(1), including XCO above and Penn West above on the basis tax was the sole motivation to the ephemeral participation of a new partner and involved amendments to the allocation agreement to affect same are not convincing. ...
SCC
1068754 Alberta Ltd. v. Québec (Agence du revenu), 2019 SCC 37, [2019] 2 SCR 993
Because in its view s. 462(1) , at least, applies to the Demand, the connection between the Calgary Branch and National Bank is severed. ... First, it argues that the so-called “Branch Entity Rule” applies to sever any connection between National Bank and the Calgary Branch, such that in issuing the Demand, the ARQ impermissibly compelled the production of documents from a branch outside its territorial jurisdiction. ...
FCTD
McCallum v. Peter Ballantyne Cree Nation, 2019 FC 898
Arrange facilities to conduct a Nomination Meeting, advance polls, and the General Election; ensure the facilities have internet connection & computers available for all polling stations. ….. viii. ... He also states that this was filed in connection with the Appeal Hearing. [48] I would first note that s 8(e) is concerned with the second stage of the appeal process, the Appeal Hearing, and that these exhibits, other than the Respondent’s appeal letter and Candidate’s Affidavit, do not form part of the Certified Tribunal Record [CTR]. ...
SCC
Fleming v. Ontario, 2019 SCC 45, [2019] 3 SCR 519
In the past, this Court has only recognized common law police powers that involve interference with liberty where there has been some connection with criminal activities. ... For example, in Figueiras, the Ontario Court of Appeal said: “If the interference with individual rights bears no rational connection to the duty being performed or is not effective in furthering the police duty, then surely it is not a ‘necessary’ interference” (para. 93). ...