Search - connection
Results 421 - 430 of 15463 for connection
TCC (summary)
Sénéchal v. The Queen, 2011 DTC 1357 [at at 1997], 2011 TCC 365 (Informal Procedure) -- summary under Subparagraph 6(1)(b)(vii)
He also stated (at para. 34): [T]he meal allowances that were included in the appellants' income were paid in connection with the appellants' performance of their duties within the municipality of Saguenay. ...
FCTD (summary)
Fourt v. The Queen, 91 DTC 5631, [1991] 2 CTC 311 (FCTD) -- summary under Principal Residence
Where there is credible evidence, as there is here, of actual use and enjoyment by the taxpayer of the contiguous land in connection with her house, and such use and enjoyment is not of an exaggerated or a natural sort, a great deal of weight must be attached to it in assessing whether such use can be reasonably regarded as contributing to the taxpayer's use and enjoyment of his residence. ...
TCC (summary)
Mackinnon v. The Queen, 2008 DTC 2052, 2007 TCC 658 -- summary under Legal and other Professional Fees
The Queen, 2008 DTC 2052, 2007 TCC 658-- 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 After noting (at para. 25) the distinction "between fees incurred to affirm a right and those incurred to acquire a right", Angers J. found that legal fees incurred by the taxpayer in connection with recovering an amount equal to the value of her son's RRSP which was wrongfully paid to his estate rather than to her, plus interest thereon, were fully deductible given that these fees were incurred "in order for the appellant to have returned to her that which was rightfully hers after the passing of her son, and they were not incurred for the purpose of acquiring a right" (para. 26). ...
FCTD (summary)
Automatic Toll Systems (Canada) Ltd. v. MNR, 74 DTC 6060, [1974] CTC 30 (FCTD) -- summary under Contract or Option Cancellation
Expense- Contract or Option Cancellation in-kind lump sum payment to cancel agreement with market influencer was deductible The taxpayer agreed to pay a company owned by an individual ("Bastien") with political connections a fee equal to 10% of all sales or rentals secured by the company during a six-year period from the Quebec Autoroute Authority. ...
FCA (summary)
The Queen v. Phyllis Moore, 90 DTC 6200, [1990] 1 CTC 311 (FCA) -- summary under Subparagraph 8(1)(h)(i)
Phyllis Moore, 90 DTC 6200, [1990] 1 CTC 311 (FCA)-- summary under Subparagraph 8(1)(h)(i) Summary Under Tax Topics- Income Tax Act- Section 8- Subsection 8(1)- Paragraph 8(1)(h)- Subparagraph 8(1)(h)(i) It was an implied term of a school principal's employment contract that she travel away from the school premises in connection with such matters as attending principals' meetings away from her school, attending evening meetings at her school and participating in extracurricular activities. ...
EC summary
Utah Co. of Americas v. MNR, 59 DTC 1275, [1959] CTC 496 (Ex Ct) -- summary under Paragraph 111(5)(a)
I find here no inter-connection, interlacing or interdependence and no unity embracing these two operations. ...
EC summary
Canadian Fruit Distributors Ltd. v. MNR, 54 DTC 1145, [1954] CTC 284 (Ex. Ct.) -- summary under Nature of Income
.)-- summary under Nature of Income Summary Under Tax Topics- Income Tax Act- Section 9- Nature of Income income reduced to nil by obligation to pay The taxpayer, which was the subsidiary of a non-profit fruit growers' non-share corporation, agreed with its parent that the parent would pay schedular "estimated charges" from time to time to the taxpayer for the taxpayer's services in connection with marketing the fruit products of the parent, and that the taxpayer would repay to the parent an amount equal to the difference between its receipts for the fiscal year (which included revenues for marketing services which it provided to third parties) and its operating expenses. ...
SCC (summary)
British Columbia Power Corporation, Limited v. Minister of National Revenue, 67 DTC 5258, [1967] CTC 406, [1968] S.C.R. 17 -- summary under Income-Producing Purpose
Minister of National Revenue, 67 DTC 5258, [1967] CTC 406, [1968] S.C.R. 17-- summary under Income-Producing Purpose Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Income-Producing Purpose The taxpayer incurred various expenses in connection with communicating with its shareholders respecting B.C. legislation under which its shares of a public utility company (which represented its principal asset) were expropriated and respecting the progress of its successful action to have such legislation declared ultra vires. ...
Decision summary
P & O (Dover) Ltd. v. Commissioners of Customs and Excise, [1992] V.A.T.T.R. 221 -- summary under Recipient
Commissioners of Customs and Excise, [1992] V.A.T.T.R. 221-- summary under Recipient Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Recipient employer the recipient of criminal counsel services The appellant along with seven individual employees was charged with manslaughter in connection with the sinking of its vessel. ...
TCC (summary)
Pellizzari v. MNR, 87 DTC 56, [1987] 1 CTC 2106 (TCC) -- summary under Subsection 15(1)
MNR, 87 DTC 56, [1987] 1 CTC 2106 (TCC)-- summary under Subsection 15(1) Summary Under Tax Topics- Income Tax Act- Section 15- Subsection 15(1) benefit qua employee Before going on to find that the taxpayer had received income from employment under s. 5(1) as a result of a corporation of which she was shareholder, director and officer paying all the legal expenses incurred in connection with defending her and the corporation against criminal charges, and before finding that this payment of her share of the legal fees by the taxpayer was made because she was an officer of the corporation, not because she was a shareholder, Couture C.J. stated (at p. 57): "If a taxpayer is a shareholder and officer of a corporation and he or she receives a benefit or advantage from the corporation this is not, of itself, conclusive of the fact that the benefit or advantage was conferred on the taxpayer in his capacity of shareholder. ...