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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. ...

In order to expedite and facilitate our audit, we will require a clear understanding of all entities with which you had a connection or affiliation during the taxation years noted above. … Please send us back the attached questionnaire fully completed within 30 days …. ...

In reversing the Court of Quebec, and in finding that the taxpayers realized capital gains, Rochette JCA noted the absence of any connection between the taxpayers’ employment and real estate, their absence of prior dealings in real estate, their initial intention of generating additional income on retirement and the decision to sell being brought on by the birth of a daughter to one, the low cost in dividing into co-ownership units and the low commercial risk associated with this step, and the sale of all the units occurring within the same year. ...

Ltd. v Li, 2020 BCSC 65-- summary under Subsection 164(1) Summary Under Tax Topics- Income Tax Act- Section 164- Subsection 164(1) CRA could be directed to pay an excess s. 116 remittance to the taxpayer’s secured creditors No s. 116 certificate was obtained on a court-approved sale of a Vancouver property (arising in connection with foreclosure proceedings) by the Hong Kong owner (Mr. ...

In rejecting Roofmart’s reliance on the statement in Hydro-Québec that "[w]hen the group is generic and has no connection to the ITA, and information can be requested outside of the scope of the ITA (such as identifying the business clients of a public utility) there is no longer any limit on the fishing expedition," Rennie JA stated (at para 37) that this “passage is not a legal test but analysis of whether, on the facts of that case, there was an ‘ascertainable group’ and whether the information was required for the purposes of verifying compliance,” and that ”the suggestion in the reasons that the information sought was available through other means and therefore could not be obtained through a UPR [unnamed person requirement] is inconsistent with this Court’s jurisprudence, and ought not to be followed.” ...

The Queen, 2020 TCC 50 (Informal Procedure), aff'd 2022 FCA 115-- summary under Paragraph 250.1(a) Summary Under Tax Topics- Income Tax Act- Section 250.1- Paragraph 250.1(a) s. 250.1 applies only to persons who would not be taxpayers under Oceanspan An individual with no connection to Canada paid a lot in tuition fees while in attendance at U.S. universities prior to 2012 then, on immigrating to Canada, claimed his purported unused tuition tax credits as a deduction from Canadian tax. ...