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Such surrenders occurred (and were previously contemplated in agreements with purchaser corporations to occur) in connection with the acquisition of all their shares by unrelated corporate purchasers. ...

Rousseau left Quebec solely for work purposes and that he never had the intention to sever his connections with Quebec, which was the place with which he maintained his strongest links between 2003 and 2011. ...

In connection with finding (at para. 50, TaxInterpretations translation) that “the assessment of Motostar was completely void, having been made respecting a non-existent person without legal standing”), Cameron JCQ noted the contrast in wording between s. 306 of the Business Corporations Act (Quebec) (“QBCA”) (which did not apply to the type of dissolution engaged in by Motostar) and s. 313 (which did). ...

-resident GE company (“GEII”), who were then “deputed” to them, and (ii) services of Indian-resident employees of an Indian GE company (“GEIIPL,” with the term “GE India” apparently also referring to GEIIPL) whose services were charged out to them on a cost-plus basis, in connection with the marketing of their products, e.g., gas turbines, to Indian customers. ...

In finding that the Customer Cash Contributions were ordinary income to the Distributors, Moshinsky J stated (at para. 165): As the Distributors’ businesses included connecting new customers to the electricity network, and as the Customer Cash Contributions were gains (in the sense that they were amounts derived) in respect of new connections, it follows that they constituted ordinary income …. ...

However, this was essentially irrelevant to the point that the implied waivers nonetheless had been given (albeit, in connection with objecting to reassessments that were replaced by, and, therefore, voided by, the second reassessments.) ...

That arrangement took place in Australia, and accordingly, because the scheme was the “proximate” origin of the profits earned, and because of the other connections with Australia summarised by the primary judge … including the location of the mine in Western Australia, those profits had a source in Australia. ...

She went on to accept Fontaine’s testimony that he had used another law firm in connection with his divorce, and that the action (brought by her as a former supplier to the Kyard business) had been defended as a threat to Kyard. ...

Both were now Canadian citizens, and neither one has any real ongoing connection with the U.S. ...

She stated that she filed late because she was away from Fredericton from February to May 2016, and did not have the necessary documents to file on time, and in connection with the second-level review (where her application was also rejected), noted her reliance on her telephone call. ...