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(Educational Connections) v. M.N.R., 2012 TCC 137         Dockets: 2011-593(CPP) 2011-597(EI)   BETWEEN:   WORLDWIDE SCHOOL SEARCH AND RELOCATION SERVICES INC., c.o.b. as EDUCATIONAL CONNECTIONS, Appellant, and   THE MINISTER OF NATIONAL REVENUE, Respondent.  ____________________________________________________________________   Appeal heard on March 7, 2012 at Toronto, Ontario   By: The Honourable J.M. ... Citation: 2012 TCC 137 Date: 20120426 Dockets: 2011-593(CPP) 2011-597(EI)   BETWEEN:   WORLDWIDE SCHOOL SEARCH AND RELOCATION SERVICES INC., c.o.b. as EDUCATIONAL CONNECTIONS, Appellant, and   THE MINISTER OF NATIONAL REVENUE, Respondent.     ... CITATION:                                       2012 TCC 137   COURT FILE NOS.:                         2011-593(CPP) and                                                           2011-597(EI)   STYLE OF CAUSE:                          WORLDWIDE SCHOOL SEARCH AND RELOCATION SERVICES INC., c.o.b. as EDUCATIONAL CONNECTIONS v.                                                           ...

Given the breadth of the phrase “in connection with”, it seems clear to me that the whole of the payments from Hasbro to its purchasing agents can be said to have been made “in connection with the sale of property...”. ... There is no necessity of adding the word ‘purchase’ when referring to something “in connection with” such a contract. ... Sales of goods” would necessarily also be made “in connection with the sale of property”. ...

This connection can be established by a reasonable inference on a balance of probabilities, and does not require that the impugned law be the only or dominant cause of the prejudice suffered by the claimant. [97] A causal connection exists where the state action is a foreseeable and necessary cause of the prejudice, but this is not the only way to establish causation. [98] The burden of establishing this connection is on the Appellants. ... A reasonable inference could be drawn that a sufficient causal connection exists between the requirements and the Appellants’ poverty. ... That being said, a s. 1 analysis requires a rational connection, similar to a s. 7 arbitrariness analysis. ...

Similarly, it would add words to the Act to read subsection 181(5) as requiring that an amount have a primary connection with a commercial activity. (2) Context [28] The context of subsection 181(5) supports the above textual interpretation. ... The absence of a similar constraint in subsection 181(5) indicates that Parliament did not intend to require a higher degree of connection between the amount paid for the redemption of the coupon and the registrant’s commercial activity. ... Moreover, subsection 181(5) does not require that the amount paid have a “primary” or “exclusive” connection with a commercial activity. ...

Jaques receive a benefit in 1999 in connection with the construction of the Slopes House? ... Issue: Did Park Haven have unreported income in 1997 in connection with Patrick House, and if so, how much? ... Did the Jaques receive shareholder benefits in 1999 in connection with the Furnishings? ...

There were three important connections made between the Perry shaft and the Springer shafts: (a) The connection at the 975 foot level. ... (b) The connection at the 2,000 foot level. This connection served a number of important purposes. ... (c) The connection at the 275 foot level. As above stated, the main purpose of this connection was to provide backfill necessary in the Perry workings from the Springer workings. ...

Requiring a military connection test is unlikely to result in further backlogs in civilian courts. ... Supreme Court later overruled O’Callahan and jettisoned the “service-connection” test in Solorio v. ... With these concerns as our guide, we turn next to discussing the military connection test.   ...

The sole constraint placed on the Minister is that a rational connection must exist between the information sought and the administration and enforcement of the ITA (Saipem at para 26). ... However, the Applicant asserts that the record does not demonstrate a rational connection between the particular material requested and the residency issue. ... I am satisfied that the information and documentation about those transactions sought through the RFI may be relevant to the residency issue or, put differently, there is a rational connection between the two. ...

Notably he added, “ Parliament has added the phrases ‘in the course of’ and ‘by virtue of’ to the phrase ‘in respect of’ in order to emphasize that only the smallest connection to employment is required to trigger the operation of the section.” ... The SCC does specifically speak to this and proceeds to decide Savage on the basis that the benefit therein was a tax exempt “ prize ” per paragraph 56(1)(n). [60]   In any event as to Savage, the broad wording of paragraph 6(1)(a) requires only the slightest connection between the benefit and employment. ... And, at risk of undue repetition, that connection was readily met for Mr. ...

Facts in connection with the fair market value of the Complex [4]      The following is a comparison of the conclusions of the Minister's appraiser, Mr. ... Facts in connection with penalties and substantial completion [8]      Mr. ... This advice was given specifically in connection with the Complex. The Appellant suggests I should give little weight to this meeting as Mr. ...