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Ordinarily, this is only possible in connection with commercial activities in which the organization might engage, since the consumers with whom it deals in connection with its educational activities are not subject to the payment of GST (see Centre Provincial de Ressources Pédagogiques v. ... In this connection we note that in its memorandum the appellant itself described the operation carried out as [TRANSLATION] "the acquisition of intellectual property rights for the purpose of making a supply by licences to exploit and market".- "Used... otherwise than in making the supply" [18] For the very reasons which we have given in the preceding paragraph, it is not possible to say here that the property (the licence) was used by the appellant in any way or at any time whatsoever otherwise than in making the supply. [19] Accordingly, it is not necessary to consider what is referred to by the words "immediately before the time tax would be payable in respect of the supply if it were a taxable supply", since there was never any use by the appellant otherwise than in making the supply. [20] The appellant therefore clearly cannot succeed, since it does not meet the second and third requirements of paragraph 2(c). [21] Consequently, we do not have to rule on the question of whether the fourth requirement_ in commercial activities_ was met. ... 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. [32] The question first arose in criminal law because of section 19 of the Criminal Code, which lays down the rule that "ignorance of the law... is not an excuse". ...

He ruled that there was no evidence that the fishing activity of the Company which gave rise to the appellants" income had any close connection with the Reserve, nor any evidence to show that the Company carried on its business in a way that is different from fishing companies owned and operated by non-Indian interests. ... The Motion and the Background to its Presentation On June 16, 1999, the Native Indian Brotherhood of British Columbia sought leave to intervene in this appeal and be permitted to file historical documents regarding an alleged connection between reserve allotments to coastal Indian Bands and the fishing activities of these Bands. ... In this regard, the Tax Court judge found at page 15 of his decision that "there is no evidence that the fishing activity of the Company which gives rise to the incomes of the Appellants has any close connection with the Reserve, or any historic, social or cultural connection with either the Band or the Reserve". ...

In this connection, it is important to note that the Federal Court of Appeal recently ruled that the law of evidence before administrative decision-makers is governed exclusively by their empowering legislation and any policies consistent with that legislation: Vancouver Airport Authority v Commissioner of Competition, 2018 FCA 24 per Stratas, Boivin, Laskin JJA at para 25: [25]   The law of evidence before administrative decision-makers is not necessarily the same as that in court proceedings. ... For example, it is the nature and extent of the interest or connection with the litigation or a party thereto which matters, not the mere fact of the interest or connection; the existence of some interest or a relationship does not automatically render the evidence of the proposed expert inadmissible..... ... This finding also prevented the Appeal Panel from considering its duty to resolve in favour of the Applicant “any doubt, in the weighing of the evidence, as to whether the applicant... has established a case”, as required by subsection 39(c). [51]   In connection with section 3 of the VRAB Act, I draw further support from the findings of the Federal Court of Appeal in Cole, which states at para 88: [88]   In my view, these provisions mandate an interpretation of the level of causal connection that is required by the phrase “directly connected with” that will facilitate, rather than impede, the awarding of pensions to members of the armed forces who have been disabled or have died as a result of military service. ...

These steps had been easily accomplished on a day-to-day basis because of their close proximity and connection. ... It had, on previous occasions given the accommodation to the individual principals of the actual business connection.... ... She had a close connection with the directors of each company and knew of the debtor's ability to repay the loans. ...

Mr Leier stated that the time devoted by JP to work in connection with the leases averages about one hour per month or twelve hours per year. ... These are examples of services rendered by JP in connection with the leases. The activities of JP in connection with the leases must be treated, in so far as these cases are concerned, as activities of King George. ...

Charron (Exhibit 1-1) in connection with the notarial contract of June 2, 1986. ... The following is a passage from his testimony in this connection: [TRANSLATION] 129 Q. ... L’Ecuyer in connection with the transaction which is at issue in this Court. ...

The Appellant also made the following remarks in connection with the payment for his services: MR. ... In this connection, the following excerpt from the transcript is of some interest: MR. ... In this connection, he referred to the case Winemaker v. R., [1995] 2 C.T.C. 2992 (T.C.C.); (1995), 96 D.T.C. 6040 (Fed. ...

The definition requires that statements or representations must be made, at some time, in connection with the property that is offered for sale. If no statements or representations have ever been made in connection with a property, then that property cannot constitute a tax shelter. ... (i) Statements or Representations [22] The existence of statements or representations in connection with a property is a necessary condition for a valid shelter. ...

In reply thereto the defendant’s evidence in connection therewith, which is accepted by this Court, in its totality, is that the decision to "write down’ the estimated closing inventory unit cost from $75/MFBM to $73.175/MFBM was because the approximate $3,000 difference pro- duced thereby was non-material in a company having assets of approximately $481,000 (noting that the exact amount of the write down herein was $3,603). ... It should also be noted that in drafting the said Note #1 to Exhibit #2, in this Court’s view, the defendant complied with the policy set out in what remains, apparently, one of the most authoritative texts used by chartered accountants, in connection with inventory valuations, being Use and Meaning of “Market” in Inventory Valuation by Gertrude Mulcahy, FCA (5th printing, 1976) at page 32, where it was said: Subsequent changes in selling prices There is also a question of whether the net realizable value should be based on the selling price as at the end of the fiscal period or should take into account changes in selling prices between the end of the period and the date the Financial Statements are prepared. ... Further, there is some suggestion in the unchallenged evidence of the Crown witness, K J Almond, that officials of the Department of National Revenue had opportunity to avert any difficulties in connection with preparation of the 1974 corporation income tax return for Kiwa Lumber Ltd (being a company twice previously prosecuted, successfully, for failure to file an income tax return) by discussing any such problems with the defendant. ...

In connection with the development by the Company of its carrier telephone terminals the department of Defence Production of Canada has contributed $450,000.00 toward the Engineering Development Costs, which amount is carried in the accounts of the company as a Deferred Liability since under certain conditions as outlined in the contract between the Company and the Department the contribution must be repaid by the Company. 32. ... The Company has presented a claim to the Government of the USA in excess of $2,000,000.00 in connection with the development of carrier telephone terminals, type AN/TCC-49. ... ACCOUNTS The Contractor shall keep proper accounts and records of the cost to the Contractor of the project and of all sales of any articles derived therefrom whether made by the Contractor or by a licensee under license from the Contractor and of all expenditures or commitments made by the Contractor in connection therewith and the invoices, receipts and vouchers relating thereto. ...