Search - connection

Accordingly, the taxpayer was able to deduct his share of certain losses of the partnership notwithstanding that, in light of their awareness of the misrepresentation, the general partners (through a trustee) refused to cash the cheque or realize upon the promissory note provided by the taxpayer in connection with his subscription. ...

Although the taxpayer maintained that, given that he spent only 57 days in Canada in the year in question in connection with his duties as director, only 57/366 of this sum was taxable in Canada, Rouleau J. upheld the Minister's reassessment that 1/2 of the amount was taxable under s. 115(2)(e) in the absence of any convincing evidence that the taxpayer had devoted a significant amount of time outside Canada to the Canadian company. ...

The trial judge found that the resulting taxable benefit should be valued at the costs incurred by the school in connection with the taxpayers' children minus the tuition paid. ...

The Queen, 2003 DTC 2112, 2004 TCC 10-- summary under Section 67 Summary Under Tax Topics- Income Tax Act- Section 67 After finding that expenses incurred by the taxpayer in connection with a trip to Las Vegas by him and six other people including his wife and some Amway distributors were not deductible by virtue of not being incurred for an income-producing purpose, Lamarre J. went on to indicate that even if s. 18(1)(a) had not prohibited the deduction of the expenses, the expenses were so excessive as to be unreasonable and therefore non-deductible by virtue of s. 67, given that the expenses incurred for the trip represented one-third of gross income for the year. ...

Accordingly, it was exempt from tax under s. 7(1)(f)(i) of the Assessment Act (Ontario) (which contemplated business assessments on every person occupying land in connection with the carrying on of a financial or commercial business) notwithstanding that its members used the exchange for profit-making activity. ...

The Queen, 92 DTC 6291, [1992] 1 CTC 242 (FCTD)-- summary under Exempt Receipts/Business Summary Under Tax Topics- Income Tax Act- Section 9- Exempt Receipts/Business Leasehold inducements or allowances which a company in the retail women's clothing business received from landlords in connection with opening up 13 new stores were capital receipts. ...

The Queen, 92 DTC 6291, [1992] 1 CTC 242 (FCTD)-- summary under Expense Reimbursement Summary Under Tax Topics- Income Tax Act- Section 9- Expense Reimbursement Leasehold inducements or allowances which a company in the retail women's clothing business received from landlords in connection with opening up 13 new stores were capital receipts. ...

MNR, 91 DTC 413, [1991] 2 CTC 2622 (TCC)-- summary under Compensation Payments Summary Under Tax Topics- Income Tax Act- Section 9- Compensation Payments The taxpayer, which regularly franchised restaurants, was found to have received on income account fixturing allowances which it received in connection with leasing space which it intended to sub-lease to franchisees. ...

Gilling, 90 DTC 6274, [1990] 1 CTC 392 (FCTD)-- summary under Paragraph 8(1)(f) Summary Under Tax Topics- Income Tax Act- Section 8- Subsection 8(1)- Paragraph 8(1)(f) implied obligation to incur travel expenses in order to perform marketing duties Part of the responsibilities of the manager of a grain elevator pool was the sale on a commission basis of farm supplies, in connection with which the taxpayer attended on farmers, delivered farm supplies, and provided services on site. ...

The Queen, 99 DTC 47, [1998] 4 CTC 2584 (TCC)-- summary under Paragraph (f) Summary Under Tax Topics- Income Tax Act- Section 66.1- Subsection 66.1(6)- Canadian exploration expense- Paragraph (f) Various expenses incurred in connection with the operation and supply of a pilot mill that was used in a bulk sampling operation qualified as CEE until the date that the mining company concluded (or should have concluded) that the deposit would not show the grade required to make a production decision. ...