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FCTD (summary)

Salt v. The Queen, 85 DTC 5055, [1985] 1 CTC 57 (FCTD) -- summary under Rule 344(7)

The length or complexity of a case or the volume of work required in connection therewith are not sufficient factors by themselves to warrant a special direction as to costs under Ruler 344(7)". ...
Decision summary

Ablan Leon Limited v. MNR, 61 DTC 519 (TAB) -- summary under Contract or Option Cancellation

Because this obligation was assumed in connection with the purchase of a business, the associated payments were non-deductible capital expenditures. ...
Decision summary

Gladstone Investment Corp. v. The Queen, [1999] F.T.R. 33087, 99 DTC 5207 FCA -- summary under Improvements v. Repairs or Running Expense

Repairs or Running Expense The taxpayer paid $480,900 to the City of Montreal in connection with a land exchange with the City and relocating a city street further to the north. ...
Decision summary

Galcom International Inc. v. The Queen, docket 2000-612 -- summary under Subsection 260(1)

The Queen, docket 2000-612-- summary under Subsection 260(1) Summary Under Tax Topics- Excise Tax Act- Section 260- Subsection 260(1) A charity that purchased various components, assembled them into solar-powered, fixed-tuned radios, and exported the radios for use in connection with evangelical activities in third-world countries was not eligible for the rebate under s. 260(1) because the property that was supplied to it (radio components) was not the same property that was exported by it (radios). ...
Decision summary

Whitehouse v. Ellam, [1995] BTC 284 (Ch. D.) -- summary under Paragraph 251(1)(c)

.)-- summary under Paragraph 251(1)(c) Summary Under Tax Topics- Income Tax Act- Section 251- Subsection 251(1)- Paragraph 251(1)(c) The written assignment by the Netherlands judgment creditor of an insolvent company of debt for a nominal amount to the taxpayer and the other shareholder of the company was an acquisition "by way of a bargain made at arm's length" for purposes of s.29A(1) of the Capital Gains Tax Act 1979 given that the taxpayer had no relevant connection with the creditor. ...
TCC (summary)

412237 Ontario Ltd. v. The Queen, 94 DTC 1022, [1994] 1 CTC 2177 (TCC) -- summary under Legal and other Professional Fees

These amounts were non-deductible given the inability of the taxpayer to establish some connection between the earning of income and the payment of the fees. ...
FCA (summary)

French v. Canada, 2003 DTC 5723, 2003 FCA 433 -- summary under Section 87

Canada, 2003 DTC 5723, 2003 FCA 433-- summary under Section 87 Summary Under Tax Topics- Other Legislation/Constitution- Federal- Indian Act- Section 87 The employment income earned by Indian employees residing in the National Capital Region and working for the Department of Indian Affairs and Northern Development in jobs relating to Aboriginal issues did not have a sufficient connection to a reserve to justify a conclusion that their income was located on a reserve. ...
TCC (summary)

Pappas Estate v. MNR, 90 DTC 1646, [1990] 2 CTC 2132 (TCC) -- summary under Legal and other Professional Fees

MNR, 90 DTC 1646, [1990] 2 CTC 2132 (TCC)-- summary under Legal and other Professional Fees Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Legal and other Professional Fees Legal expenses incurred by an estate with an extensive portfolio of investments in connection with obtaining probate; determining the extent of the entitlement of various beneficiaries; managing and supervising the investments; devising and carrying out plans to minimize taxation of the estate, beneficiaries and companies within the group; and investing in liquid assets; were non-deductible. ...
TCC (summary)

Brock v. MNR, 91 DTC 1079, [1991] 2 CTC 2121 (TCC) -- summary under Section 34

MNR, 91 DTC 1079, [1991] 2 CTC 2121 (TCC)-- summary under Section 34 Summary Under Tax Topics- Income Tax Act- Section 34 Lamarre Proulx J. rejected a submission that under the laws of Ontario interim accounts rendered by a solicitor are not enforceable and, in any event, found that the statements of account rendered in connection with the taxpayer's law practice were not worded so as to constitute true interim bills of account. ...
FCTD (summary)

Duthie Estate v. The Queen, 95 DTC 5376, [1995] 2 CTC 157 (FCTD) -- summary under Start-Up and Liquidation Costs

The Queen, 95 DTC 5376, [1995] 2 CTC 157 (FCTD)-- summary under Start-Up and Liquidation Costs Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Start-Up and Liquidation Costs The taxpayer commenced to use personal-use capital property in connection with a real estate development business at the time he made a decision to proceed with the development of the property as a condominium project and retained architects, project managers and other professionals to assist with the development plans. ...

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