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There is a clear connection to Canada and, due to the tax immunity enjoyed in the host country, there is an ability to pay. ... However, the Appellant maintained the Canadian connections with Canada in case he did return. ... The decision seems to concentrate on the point that the connections to the U.S.A. seemed more important than those regarding Canada. ...

For convenience, I repeat subsection 212(5). 212(5) Every non-resident person shall pay an income tax of 25 per cent on every amount that a person resident in Canada pays or credits, or is deemed by Part I to pay or credit, to him as, on account or in lieu of payment of, or in satisfaction of, payment for a right in or to the use of (a) a motion picture film, or (b) a film, video tape or other means of reproduction for use in connection with television (other than solely in connection with and as part of a news program produced in Canada), that has been or is to be used or reproduced in Canada. ... Thus, since 1962, the Act has provided liability for tax on payments for a right in or to the use of two different products “motion picture films or films or video tapes for use in connection with television". ... The latter suggestion does not directly assist; by giving the widest “connection between two related subject matters”, in the words of Dickson J., here "rents and royalties" and “motion picture films”, one cannot ascertain the meaning to be ascribed to “motion picture films” in the context of this case. ...

("Kruger") in 1974 in connection with Kruger's major expansion of a manufacturing facility at Trois Rivières, P.Q. ...

I say this because that individual first referred to is next referred to in connection with his family. ...

All students are given access to a dedicated online connection similar to a "chatroom" for each course so that issues can be discussed among the students and with the tutors. ...

.)), or where the claimant is seeking financial compensation in connection with allegations of unlawful or wrongful acts by an employer (Guenette v. ...

We are of the view that the funds in question were received by the respondent during the normal course of the operation of his investment business and that although he used the funds for a purpose not authorized by the investors, the dishonest act on his part took place in connection with the operation of his business. ...

C.R. 408; [1969] C.T.C. 353; 69 D.T.C. 5278 at 361 (D.T.C. 5283) analyzed the question this way: Applying these principles, as I understand them, to materials prepared by accountants, in a general way, it seems to me (a) that no communication, statement or other material made or prepared by an accountant as such for a business man falls within the privilege unless it was prepared by the accountant as a result of a request by the business man's lawyer to be used in connection with litigation, existing or apprehended; and (b) that, where an accountant is used as a representative, or one of a group of representatives, for the purpose of placing a factual situation or a problem before a lawyer to obtain legal advice or legal assistance, the fact that he is an accountant, or that he uses his knowledge and skill as an accountant in carrying out such task, does not make the communications that he makes, or participates in making, as such a representative, any the less communications from the principal, who is the client, to the lawyer; and similarly, communications received by such a representative from a lawyer whose advice has been so sought are none the less communications from the lawyer to the client. ...

As a result I assumed the unnamed persons were Italian citizens, although with a Swiss connection, and that they wished investments out of Italy. ...

  [4]              The Appellant acquired a Free Miner Certificate in March 2000 and began reporting expenses in connection with his mining activities in 2002. ...