Search - connection
Results 11981 - 11990 of 15463 for connection
ABQB decision
R. v. Warawa, 98 DTC 6471, [1998] 1 CTC 345 (Alta. Q.B.)
It is significant that he goes on to say “in addition to questioning Warawa in connection with above items take note (or photocopy) of what records would be available for seizing in the future”. ... Gaudet, supra, where at p. 22 he says as follows: I want to point out that in my opinion, neither the Norway case, supra, nor the Jarvis, case, supra, nor any of the other cases cited by defence counsel stand for the proposition that in a situation, such as the case at bar, where national revenue, without any prior indication of tax evasion by the taxpayer set out to do an audit, at some time later, the audit becomes an Investigation, Revenue Canada is then precluded from using the information secured during the audit either during the investigation or in connection with any search warrant related thereto. ...
TCC
Baillargeon v. MNR, 92 DTC 1212, [1991] 2 CTC 2525 (TCC)
In the former case, in his analysis of this expression Thurlow, J. stated [see 4.02(2), at 214 (D.T.C. 6183]: (It may not always be easy to decide whether an expense has so arisen but it seems to me that the words “in the course of" in paragraph 11(1)(cb) are not a reference to the time when the expenses are incurred but are used in the sense of “in connection with” or "incidental to" or “arising from" and refers to the process of carrying out or the things which must be undertaken to carry out the issuing or selling or borrowing for or in connection with which the expenses are incurred) In Côte-Reco Inc. ...
SCC
Canadian Industrial Gas & Oil Ltd. v. Government of Saskatchewan et al., 80 DLR (3d) 449, [1978] 2 SCR 545
In this connection, there is the important fact that 98 per cent of all crude oil produced in Saskatchewan is destined for export from the Province either to Eastern Canada or the United States of America. ... This was a test applied, in another connection, by Duff J. (as he then was) in Gold Seal Limited v. ...
SCC
National Corn Growers Assn. v. Canada (Import tribunal), [1990] 2 SCR 1324
After reviewing the scheme of SIMA and observing that it refers to the GATT in "several key areas", MacGuigan J. concluded, at p. 550, that SIMA "would appear to involve an acceptance of the whole scheme of the Code, which requires a causal connection between subsidized imports and domestic injury". ... In the process, the legislature has made clear that neither this Court nor the Federal Court of Appeal is to act as a normal appellate court in connection with the Canadian Import Tribunal's findings. ...
TCC
Oxford Properties Group Inc. v. The Queen, 2016 TCC 204, rev'd 2018 FCA 30
The court is only required to consider whether the series was taken into account when the decision was made to undertake the related transaction in the sense that it was done “in relation to” or “because of” the series (Trustco, at para. 26). [47] Although the “because of” or “in relation to” test does not require a “strong nexus”, it does require more than a “mere possibility” or a connection with “an extreme degree of remoteness” (see MIL (Investments) S.A. v. ... In the end, it will be the “because of” or “in relation to” test that will determine, on a balance of probabilities, whether a related transaction was completed in contemplation of a series of transactions. [15] [66] It also concluded that subsection 248(10) allows either prospective or retrospective connection of a related transaction to a common law series. [16] Further, if I find that there was a series of transactions which resulted in a tax benefit, the finding that one transaction in the series was an avoidance transaction will satisfy the requirements of subsection 245(3). [17] [67] Counsel for the Appellant did not dispute during the hearing that the sale of RAC LP to OMERS Realty Corporation was part of the series of transactions that the parties agreed contained one or more “ avoidance transactions ”. ...
TCC
Côté v. The Queen, docket 92-2773-IT-G
He was prohibited from acting directly or indirectly as an appraiser, promoter, broker or consultant in connection with gifts of works of art to non-profit organizations, such as charities, and in particular museums and fabriques. ... Demers also made a connection between invoices from the Galerie des Maîtres Anciens and Univers du Rail Inc. ...
TCC
Dynamex Canada Corp. v. M.N.R., 2010 TCC 17
WHEREAS the Company carries on a same day transportation and distribution business and is licensed to use certain trademarks in connection therewith; AND WHEREAS the Owner Operator owns/leases a vehicle [6] (the “Vehicle”) suitable to the business and the provision of services for the Company, and the Owner Operator desires to perform, and the Company desires to engage the Owner Operator to perform, certain distribution and delivery services for the Company; AND WHEREAS, subject to the prevailing provisions of any applicable Collective Agreement, the Company and the Owner Operator desire to fix and determine between themselves their respective rights and obligations: NOW THEREFORE in consideration of the mutual covenants and agreements hereinafter contained the parties hereto agree as follows: 1. ... Uniforms for purchase by the Owner Operator at the Company’s cost price, plus applicable taxes, payable by the Owner Operator on invoice therefore. ii) When the Company’s trademarks, tradename, logos or decals are displayed or shown on a uniform or the Owner Operator’s motor vehicle, not to place any other name, notice, advertising, decal or painting of any nature or kind whatsoever on the uniform or motor vehicle other than as expressly permitted by the Company which may not be unreasonably and arbitrarily withheld. iii) The trademark “Dynamex ”, distinctive colour and designs used in connection therewith, are all the property of the Company and their use accrues wholly to the benefit of the Company. ...
SCC
Atlantic Smoke Shops Ltd. v. Conlon and Attorney-General for Quebec, [1941] SCR 670
Under the provisions of the Act, tobacco enters perfectly free into the Province; but the consumer is taxed in connection with the consumption of a commodity which is in the consumer's possession in the Province. ... Perhaps I should in this connection mention s. 7 in addition to the other sections I have referred to. ...
TCC
Morrison v. The Queen, 2018 TCC 220, aff'd sub nom. Eisbrenner v. Canada, 2020 FCA 93
Eisbrenner each testified that there was no connection between the cash donation identified in the promotional materials as “ Stage 1 ” and the balance of the steps identified in the promotional materials as “ Stage 2 ”, and that there was no obligation to make a cash donation to be considered as a potential Class A beneficiary of CHT. [41] [36] Mr. ... Rosenberg and Marigold recommend thus have no connection with the transactions prices actually charged and received by manufacturers for generic drugs in Canada. ...
FCTD
Canadian Association of Refugee Lawyers v. Canada (Citizenship and Immigration), 2019 FC 1126
In my view, this objection is more appropriately addressed in connection with the issue that CARL has raised regarding the Chairperson’s failure to consult with the public before issuing the China JG. [82] CARL also maintains that it is improper to raise a factual finding to the level of a jurisprudential guide because country conditions are constantly changing. ... In connection with transportation and travel, the JG also notes that consideration must be given to Chairperson Guidelines 4: Women Refugee Claimants Fearing Gender-Related Persecution. [118] The JG concludes with the statement that “it is my view tha[t] an assessment in line with the framework set out above would be broadly applicable and determinative in a variety of Nigerian claims where the fear is of non-state actors, and as below, would have to be applied in any individual appellant’s particular circumstances ”: at para 30 (emphasis added). [119] Considering the passages that I have underlined in the various quotes above, I am satisfied that the Nigeria JG does not unlawfully fetter the discretion of Board members or improperly constrain their freedom to decide cases that may come before them according to their own conscience. ...