Search - connection
Results 461 - 470 of 15463 for connection
Decision summary
Toronto Blue Jays Baseball Club v. Minister of Finance (Ontario), 2005 DTC 5360 (Ont. CA) -- summary under Subsection 400(2)
McMurtry C.J.O. stated (at p. 5364) that the "teams' connection with non-Ontario venues and the control of these venues is relatively so transitory that they cannot be considered to be fixed places of business". ...
Decision summary
Toronto Blue Jays Baseball Club v. Minister of Finance (Ontario), 2005 DTC 5360 (Ont. CA) -- summary under Permanent Establishment
McMurtry C.J.O. stated (at p. 5364) that the "teams' connection with non-Ontario venues and the control of these venues is relatively so transitory that they cannot be considered to be fixed places of business". ...
TCC (summary)
Verreault v. The Queen, 2012 DTC 1285 [at at 3872], 2012 TCC 293 (Informal Procedure) -- summary under Section 87
That her employer was Native Leasing Services or that most of her students were status Indians were not enough to establish such a connection. ...
TCC (summary)
Bouchard v. The Queen, 2013 DTC 1203 [at at 1083], 2013 TCC 247 (Informal Procedure) -- summary under Business Source/Reasonable Expectation of Profit
The Queen, 2013 DTC 1203 [at at 1083], 2013 TCC 247 (Informal Procedure)-- summary under Business Source/Reasonable Expectation of Profit Summary Under Tax Topics- Income Tax Act- Section 3- Paragraph 3(a)- Business Source/Reasonable Expectation of Profit LP for daughter's tennis training expenses When his daughter was nine years old, the taxpayer created the "Tennis Mania LP," which used the funds contributed by him to reimburse him for expenses incurred by him in connection with her training and development as a tennis player. ...
FCTD (summary)
Walls v. The Queen, 76 DTC 6309, [1976] CTC 501 (FCTD) -- summary under Paragraph 8(1)(g)
Detroit did not constitute part of the metropolitan area of Windsor as it was not integrated with the City of Windsor: "for example, there are no common infrastructures, municipal services such as streets, water, fire or police protection, and there is no political connection." ...
FCTD (summary)
Breakell v. The Queen, 91 DTC 5419, [1991] 2 CTC 77 (FCTD) -- summary under Real Estate
A submission that the land had originally been acquired for use in connection with an exotic cattle operation was rejected given that the land was known to be in the path of development, the price paid for the land greatly exceeded what one would expect from a purchaser looking for farming land, the partnership agreement among the taxpayers described them as "land developers", and not all the participants in the cattle operation were invited to participate in the land venture. ...
TCC (summary)
Y S I's Yacht Sales International Ltd v. The Queen, 2007 TCC 306 -- summary under Subsection 169(1)
The Queen, 2007 TCC 306-- summary under Subsection 169(1) Summary Under Tax Topics- Excise Tax Act- Section 169- Subsection 169(1) Woods, J. accepted that an agreement pursuant to which the appellant ("YSI") agreed to contract with suppliers in connection with refurbishing a yacht and to charge the other party to the contract ("Platinum") a 5% mark-up on some of the purchases, did not establish an agency relationship between YSI and Platinum. ...
Decision summary
Clark v. Oceanic Contractors Inc., [1982] BTC 417, [1983] 1 All E.R. 133 (HL) -- summary under Paragraph 153(1)(a)
., [1982] BTC 417, [1983] 1 All E.R. 133 (HL)-- summary under Paragraph 153(1)(a) Summary Under Tax Topics- Income Tax Act- Section 153- Subsection 153(1)- Paragraph 153(1)(a) carrying on trade was sufficient connection to jurisdiction nS.204(1) of the Income and Corporation Taxes Act 1970 stated baldly that "income tax shall... be deducted or repaid by the person making payment" without (like s. 153(1) of the Canadian Act) stating explicitly that the payor, to be subject to this withholding obligation, must be a resident of or carrying on business in the jurisdiction. ...
TCC (summary)
Murphy Estate v. The Queen, 2015 TCC 8 -- summary under Effective Date
In connection with noting that the children had not disclaimed their interests in the RRSPs, V. ...
TCC (summary)
Pièces automobiles Lecavalier Inc. v. The Queen, 2014 DTC 1126, 2013 TCC 310 -- summary under Evidence
The Queen, 2014 DTC 1126, 2013 TCC 310-- summary under Evidence Summary Under Tax Topics- General Concepts- Evidence Canadian tax accountant's testimony on US tax consequences accorded little weight The taxpayer sought to establish through testimony of a Canadian tax accountant who had advised in connection with the transactions under review that an arm's length vendor (Ford U.S.) of debt and shares to the taxpayer had engaged in preliminary transactions for U.S. tax reasons rather than to accommodate a Canadian tax advantage to the taxpayer. ...