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SCC

McLaws v. Minister of National Revenue, 72 DTC 6149, [1972] CTC 165, [1974] S.C.R. 887

Its indebtebdness to the bank had increased, it had sold its real property and applied the proceeds towards the bank loan, it had taken a lease-back of the real estate and in that connection gave a chattel mortgage on the company’s equipment to the landlord. ... And the payment of fees to you in connection with the guarantee was incidental and secondary thereto to that primary purpose? ...
FCTD

Stowe-Woodward Inc. v. The Queen, 92 DTC 6149, [1992] 1 CTC 209 (FCTD)

It is argued that the plaintiff's main activity is the provision of services and that the production of "goods" in connection therewith is only incidental to the service being provided. ... As counsel for the plaintiff pointed out, under such a regime, a manufacturer or processor of a product (e.g., a chemical fertilizer) who also provided a service in connection therewith (e.g., spreading the fertilizer for his customers) would be denied the processing tax deduction. ...
FCTD

Crown Forest Industries Ltd. v. The Queen, 92 DTC 6305, [1992] 2 CTC 1 (FCTD)

Now, whilst it is asserted by some that the republic to the south has frequently exhibited more tendencies to dominate than to trade or to compete in business, that country has not yet sought to tax foreign corporations at random, but only those with some connection with the U.S. In the case of Norsk, its connection is carrying on its business from its place of management situated in the U.S.A. and in generating income effectively connected with its business. ...
FCTD

Inshore Investments Ltd. v. The Queen, 92 DTC 6162, [1992] 1 CTC 189 (FCTD)

Jones, but also from a letter addressed to him on March 15, 1979, by his own solicitor (of the firm Thorsteinsson, Mitchell, Little, O'Keefe & Davidson) in connection with Mr. ... In addition to the $1,000,000 received by Blake for the sale of the shares in Taiga, "the company also received $250,000 from Taiga in connection with management services to be rendered". ...
TCC

Bakorp Management Ltd. v. The Queen, 2015 TCC 36, aff'd supra.

The Appellant was assessed Part IV taxes in connection with dividends received for its 1993 and 1995 taxation years, initially as filed. ... Moreover, the Appellant’s T2 income tax return entered into evidence shows the payment made on account of 1995 and the parties agree it was paid on June 10, 1995. [18]         Accordingly, based on a textual, contextual and purposive approach, it would be inconsistent and unharmonious to interpret subsection 187(2) to mean that any payment made in connection with a particular year can apply to any other year, as the Appellant alleges. ...
TCC

Roy Legumex Inc. v. MNR, 90 DTC 1858, [1990] 2 CTC 2389 (TCC)

The word "attached" in subparagraph (b)(ii) contemplates more than a simple connection. ... The phrase "faisant partie" confirms that the word "attached" in the English language version of subparagraph (b)(ii) means more than a mere connection; the tangible property must be so attached to the building that it more or less becomes part of it. ...
SCC

James Richardson & Sons v. M.N.R., 84 DTC 6325, [1984] CTC 345, [1984] 1 SCR 614

These sections provide: 221. (1) The Governor in Council may make regulations … (d) requiring any class of persons to make information returns respecting any class of information required in connection with assessments under this Act, … 233. ... These considerations do not apply to demands made to classes of persons for specific kinds of information required in connection with assessments generally. ...
TCC

Stone Container (Canada) Inc. v. R., 98 DTC 1508, [1998] 3 CTC 2150 (TCC)

They import such meanings as “in relation to”, “with reference to” or “in connection with”. The phrase “in respect of” is probably the widest of any expression intended to convey some connection between two related subject matters. ...
EC decision

MNR v. Ontario Paper Co. Ltd., 58 DTC 1046, [1958] CTC 71 (Ex Ct), briefly aff'd 59 DTC 1327 (SCC)

In this connection, Lord Herschell, in Bank of England v. Vagliano, [1891] A.C. 107, 145, said: ‘‘ What, however, I am venturing to insist upon is, that the first step taken should be to interpret the language of the statute...” ... In this connection, Odgers at page 177 (supra) states: 44 Next, if possible, the construction adopted should be in accordance with the policy and object of the statute in question.’’ ...
TCC

830480 Alberta Inc. v. The Queen, 2013 DTC 1027 [at at 132], 2012 TCC 424

That question does not arise only in connection with strict liability offences, although with the growth in regulations and the multiplication of statutory offences the field of strict liability has proven to be the most fertile for the emergence of this defence. ... ]   [26]         I agree with counsel’s submission that a taxpayer can avoid late filing penalties if the taxpayer can show, on a balance of probabilities, that he or she had reasonable grounds to believe that no taxes were owed in connection with the returns that were filed late. ...

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