Search - connection

As long as the transaction has some connection with the common law series, it will, if it was completed in contemplation of the common law series, be included in the series by operation of the deeming provision in subsection 248(10).                 ...

Cassels stated he attempted to comply with all aspects of GST in connection with the various business outlets for which he was responsible. ...

The Queen, 83 DTC 5041 at 5045, Justice Dickson of the Supreme Court of Canada held that the phrase "in respect of" (in that case found in section 87 of the Act) is "probably the widest of any expression intended to convey some connection between two related subject matters". [68]          In The Queen v. ...

Any officer or servant employed in connection with the administration or enforcement of this Act, if designated by the Minister for the purpose, may, in the course of that employment, administer oaths and take and receive affidavits, declarations and affirmations for the purposes of or incidental to the administration or enforcement of this Act or regulations made thereunder, and every officer or servant so designated has for those purposes all the powers of a commissioner for administering oaths or taking affidavits. [7] The relevant provisions read as follows: (11)       Rental Properties — Notwithstanding subsection (1), in no case shall the aggregate of deductions, each of which is a deduction in respect of property of a prescribed class owned by a taxpayer that includes rental property owned by him, otherwise allowed to the taxpayer by virtue of subsection (1) in computing his income for a taxation year, exceed the amount, if any, by which (a)         the aggregate of amounts each of which is (i)                   his income for the year from renting or leasing a rental property owned by him, computed without regard to paragraph 20(1)(a) of the Act, or (ii)         the income of a partnership for the year from renting or leasing a rental property of the partnership, to the extent of the taxpayer's share of such income...           ...

Bentley's to sell. [9]      Paragraph 8(1)(f) of the Income Tax Act permits a deduction in computing income from an office or employment as follows: (f)         where the taxpayer was employed in the year in connection with the selling of property or negotiating of contracts for the taxpayer's employer, and (i)          under the contract of employment was required to pay the taxpayer's own expenses, (ii)         was ordinarily required to carry on the duties of the employment away from the employer's place of business, (iii)        was remunerated in whole or part by commissions or other similar amounts fixed by reference to the volume of the sales made or the contracts negotiated, and (iv)        was not in receipt of an allowance for travel expenses in respect of the taxation year that was, by virtue of subparagraph 6(1)(b)(v), not included in computing the taxpayer's income, amounts expended by the taxpayer in the year for the purpose of earning the income from the employment (not exceeding the commissions for other similar amounts referred to in subparagraph (iii) and received by the taxpayer in the year) to the extent that those amounts were not (v)         outlays, losses or replacements of capital or payments on account of capital, except as described in paragraph (j), (vi)        outlays or expenses that would, by virtue of paragraph 18(1)(l), not be deductible in computing the taxpayer's income for the year if the employment were a business carried on by the taxpayer, or (vii)       amounts the payment of which reduced the amount that would otherwise be included in computing the taxpayer's income for the year because of paragraph 6(1)(e). [10]     Subject only to the question of the year of deductibility I am of the view that all of the conditions permitting the appellant to deduct the payment have been met and indeed the Minister in his assumptions stated that he had allowed the majority of the employment expenses claimed. [11]     Obviously, the $100,000 was expended for the purpose of earning the income. ...

Ouellette said he was even able in certain instances to make a connection with the restaurant Cocktail Antabli belonging to Roger Merhi. ...

This explanation is questionable given that the funds in question were being held under A & A's name and there is no apparent connection between A & A and ETI. ...

This is particularly true when the person has no prior employment connection with the party who benefits from his services. ...

Dignard further stated that Coulter then went bankrupt and from that moment Place d'Embrun was in real financial trouble as it lost its connection to the money source. [13] Alfred Dignard said that, at that point, he tried to sell the first phase of the mall (Place d'Embrun). ...

At paragraphs 3 and 4 of his judgment, Létourneau, J.A. stated: "In connection with the control which characterizes master-servant relations in a contract of employment, and thus the relationship of subordination required between the employer and employee, the Tax Court of Canada deputy judge considered inter alia the following facts: (a) Mr. ...