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TCC

The Ottawa Hospital Corporation v. The Queen, 2010 TCC 53

., [1983] 1 S.C.R. 29, where the Supreme Court of Canada gave the widest possible scope to the words “in respect of” and stated:   … The phrase "in respect of" is probably the widest of any expression intended to convey some connection between two related subject matters ...
TCC

Huntley v. M.N.R., 2010 TCC 625

I dismissed this motion on the basis that the subject matter of this appeal is not the decision of the Minister in the case of Edward Huntley but the appeal of the Minister’s decision in connection with this Appellant only and that any evidence dealing with his half-brother relevant to this decision would be given such weight as this Court deems just. ...
TCC

Heritage Education Funds Inc. v. The Queen, 2010 TCC 161

Loduca acknowledged that expenses incurred by the appellant in connection with the sale of the units sold in 1999 (Exhibit R-2) were deducted in the computation of income for tax purposes. ...
TCC

The Toronto-Dominion Bank v. The Queen, 2010 TCC 275

  [45]    In this connection, I refer to paragraphs 11 and 12 of the Respondent’s written argument where he said:   11. ...
TCC

893134 Ontario Inc. (Mega Distributors) v. The Queen, 2010 TCC 357

In any event, the Appellant, as the employer of Adnan and Mohammed Nizam, is vicariously liable for those employees' authorized acts and for their unauthorized acts having a connection with the authorized acts. ...
TCC

Garage Gilles Gingras v. The Queen, 2010 TCC 343 (Informal Procedure)

  [124]      For all of these reasons, the appeals are allowed in part, and the two files should be referred back to the Agency for reassessments in both cases, given their close connection (see paragraph 115) ...
TCC

CIBC World Markets Inc. v. The Queen, 2010 TCC 460

  [28]          Appellant's counsel stated that in adopting a value-added tax over other tax systems, Parliament considered as a first principle the full recovery of GST paid or payable by any registrant acquiring goods or services in connection with making a taxable supply in the course of a commercial activity [17] and, in appellant's counsel's view, the disallowance of the disputed amount frustrates the fundamental purpose of the GST regime. ...
TCC

Craig v. The Queen, 2009 TCC 617

He admitted horseracing was not a popular avenue for entertaining clients and noted that even though his biggest client happened to be a horse breeder, which contributed to the collegial side of their relationship, it was his talents as a lawyer that brought that relationship into being, not his connection to horseracing;   i.         ...
TCC

9110-1568 Québec Inc. v. The Queen, 2009 TCC 554 (Informal Procedure)

  [57]          The term "commercial activity" is defined at subsection 123(1) of the Act, which states:   "commercial activity" of a person means   (a) a business carried on by the person (other than a business carried on without a reasonable expectation of profit by an individual, a personal trust or a partnership, all of the members of which are individuals), except to the extent to which the business involves the making of exempt supplies by the person;   (b) an adventure or concern of the person in the nature of trade (other than an adventure or concern engaged in without a reasonable expectation of profit by an individual, a personal trust or a partnership, all of the members of which are individuals), except to the extent to which the adventure or concern involves the making of exempt supplies by the person, and;   (c) the making of a supply (other than an exempt supply) by the person of real property of the person, including anything done by the person in the course of or in connection with the making of the supply ...
TCC

Johnston v. The Queen, 2009 TCC 327

Employee Leasing Inc. and since there is obviously a very close connection between O. ...

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