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Contentions The position of the appellant was that no amount was received in 1968 or in any other year in connection with the purchase of the property which could be classified as interest income; and that, with regard to the sale of parcel 3, the gain therefrom was on capital account, resulting from the acquisition and sale of capital assets. ... Mr Morton Greenglass, called for the appellant, had provided legal advice and services to the appellant in connection with the mortgage foreclosure and the defence against such foreclosure raised by Clearstream. ... In addition to the security for the loan, noted earlier, Bailey had accepted on behalf of Greenington a 12 /2% interest in the voting stock of Clearstream, certain positions on the board of directors, and he had acted on a building committee in connection with the construction contracts for the golf club grounds and facilities. ...

When in high school Chaffey worked in a law office in Welland in connection with real estate and mortgage transactions, and after completing high school he started to work full time in that office in the early 1940’s. ... A number of such companies (including Zacko Holdings Limited, previously referred to in connection with the Canadia transaction) and other companies in which the Taylor-Chaffey partnership had shareholdings, mostly minority shareholdings, are indicated briefly next herein, along with various real estate transactions in which the partnership was directly or indirectly involved: 1. ... There was evidence that money was advanced to the Taylor-Chaffey partnership by Elwood Glenn, C J Clarke and J L Fulop in connection with Canadia. ...

They did not consult their attorney about the alleged expropriation threat because they were convinced of the validity of it when they read in the news that the City of Montreal was seeking expropriation powers for land assembly purposes in connection with major developments. ... He had helped Andrews in connection with his proposals to relocate his liquor licence in a building on McGill College Avenue and the necessary soil tests had been made by Franki in 1960 and the building permit obtained, only to be cancelled soon after. ... In the present case it must be said that appellant apparently did nothing in connection with maturing or disposing of the property with a view to the sale of same, but rather eventually accepted an unsolicited offer and then only allegedly under some duress. ...

From the time the company was incorporated, Mr Graupe operated the business as if Fritz Werner Germany were already controlling it, consulting them in connection with major decisions. ... It is de jure control therefore and not de facto control which governs, so that whatever influence Fritz Werner Germany Ltd had exercised over Werner Graupe in connection with the operation of the business of respondent from its incorporation until the time it became a 55% shareholder in December 1965, and whatever interest-free loans it may have advanced or profits it may have shared in the interval, and no matter to what extent it may have been consulted during this period in connection with any major decision, it cannot be said that it had at any time de jure control over the company prior to December 1965 as it did not have control within the meaning of paragraph 39(4)(b), so respondent’s first argument must fail. ...

By the Robinson Company and the appellant for damages for fraudulent misrepresentations in connection with that transaction and for a declaration that the transaction is voided and that the Robinson Company is entitled to the return of its $580,000. 3. ... In his memorandum of November 9, 1967, previously referred to, the appellant stated that the amount owing to him by C & T at May 25, 1967 in respect of the loan to C & T under the trust agreement and interest and incidental payments in that connection, plus the 3% on the $350,000 bank loan, was $149,573.91 net, as detailed in the memorandum. ... In 1816, when Clayton’s Case (1 Mer. 585, 608) was decided, there seems to have been authority for saying that the creditor was bound to make his election at once according to the rule of the civil law, or at any rate, within a reasonable time, whatever that expression in such a connection may be taken to mean. ...

The Last Will and Testament of the deceased provided, inter alia, as follows: “I GIVE, DEVISE AND BEQUEATH all my estate of every nature and kind whatsoever unto my said Trustees upon the following trusts: 1) to allow my said wife, MARGARET OLIVE, to occupy and use as a home whatever house and lands I may own and be using as a home at the time of my death, together with all chattels including furniture, equipment, accessories, consumable stores, and articles of domestic and household use or ornament therein or used in connection therewith, until she re-marries or until she notifies my Trustees that she desires to vacate the premises, or until her death, whichever event first occurs, whereupon the said house and lands shall be sold or otherwise dealt with and distributed by my Trustees as part of the residue of my estate and in the event of the termination of her occupancy otherwise than by her death, she shall have the privilege of taking, within one month after such event, for her own use absolutely, all or some of the said chattels, any chattels not so taken to be sold or otherwise dealt with by my Trustees as part of the residue of my estate. ... To allow my said wife, MARGARET OLIVE, to occupy and use as a home whatever house and lands I may own and be using as a home at the time of my death, together with all chattels including furniture, equipment, accessories, consumable stores, and articles of domestic and household use or ornament therein or used in connection therewith, until she re-marries or until she notifies my Trustees that she desires to vacate the premises, or unitl her death, whichever event first occurs, whereupon the said house and lands shall be sold or otherwise dealt with and distributed by my Trustees as part of the residue of my estate and in the event of the termination of her occupancy otherwise than by her death, she shall have the privilege of taking, within one month after such event, for her own use absolutely, all or some of the said chattels, any chattels not so taken to be sold or otherwise dealt with by my Trustees as part of the residue of my estate. ... To pay out of the capital of my general estate my just debts, funeral and testamentary expenses and all succession duties, inheritance, estate and death taxes, whether imposed by or pursuant to the law of this or any province, state, country or jurisdiction whatsoever, that may be payable in connection with any insurance on my life or any gift or benefit given by me either in my lifetime or by survivorship or by this my Will or any codicil thereto. 5. ...

Issue [6] The issue is whether, for the purposes of qualifying for the ITC claimed, the appellant met the applicable conditions of paragraph 169(4)(a) of the ETA and the Input Tax Credit Information (GST/HST) Regulations, SOR/91-45 (the Regulations) in connection with the Lessor’s GST number. ... The witness confirmed that the Lessor’s GST number was obtained after he had asked the Lessor to provide it and that this number was in his possession before any income tax returns containing an ITC claim in connection with the Lessor were prepared. [20] With respect to the failure to send the Lessor’s GST number to the Agency in the context of the objection submitted against the 2015 income tax return, he could not recall that the agent had expressly requested the Lessor’s GST number to provide a rationale for entitlement to the ITC. [21] The witness explained that when a fax in support of the objection was sent on March 25, 2019, he attached an extract from the Registraire des entreprises relating to the Lessor proving the existence of a corporate name, Gestion 170 René-Lévesque, used by the Lessor. ... Therefore, if taxpayers are to act with any degree of certainty under such a regime, then full effect should be given to Parliament’s precise and unequivocal words. [49] The clarifications made above by the Canada Revenue Agency are supported by the wording of paragraph 169(4)(a) of the ETA and are consistent with the meaning and scope to be given to the measures described in the Regulations concerning the particulars that a registrant must obtain in connection with a supply. [50] More specifically, it does not seem appropriate that the general wording of the preamble to the definition of supporting document in the Regulations should be given a scope limited to the list that follows the preamble. ...

(In this connection, it is agreed that in respect to the bequest to The Harshman Foundation by the will of Hubert Harry Harshman deceased, that there should in any event be deducted from it, if the appellant should succeed on this appeal, the proper capital amounts which for estate tax calculation constitute the limits of the discretion given to the trustees under the will to encroach on the residue of the estate in favour of the deceased’s widow which power of encroachment is provided in paragraph 9 of the will and permits an encroachment of the income up to the sum of $10,000 in any one year and an encroachment upon the capital during the lifetime of the wife to an amount not exceeding in the aggregate 30,000.) ... The respondent in argument, submitted that “The Harshman Foundation’’ referred to in these proceedings was: (1) a chari- table trust and not a charitable organization within the meaning of Section 7(1)(d) of the Estate Tax Act; and in this connection referred to the similarity of language employed in Section 62(1) (e) of the Income Tax Act which exempts from taxation the income of certain charitable organizations in contradistinction to the language employed in Section 62(1) (g) of the Income Tax Act which is concerned with the exemption from taxation of the income of certain charitable trusts; and (2) that the gifts either in lifetime or by the will of the decedent were not “absolute and indefeasible’’ within the meaning of Section 7(1) (d) of the Estate Tax Act. ... In other words, the appellant submitted that the testator using a trust structure in fact created an ‘‘organization in Canada’’ within the meaning of Section 7(1) (d); and in this connection, the appellant relied in particular on the concluding words of the subsection, namely, that such an organization in Canada may itself be set up for the purpose of ‘‘the making of gifts to other such organizations in Canada all or substantially all of the resources of which’’ are devoted to charitable activities carried on or to be carried on by them. ...

The will also stated: ‘‘as to the bare ownership of said property, I give and bequeath it to be disposed of by my wife in her will, and in this connection I wish to recall my great love and affection for Hélène. ... In this connection, however, counsel for the respondent claims that the conditional substitution was fulfilled and that, by the interposition of the resolutory provision, respondent receives the property from her father retroactive to January 18, 1941. ... As we have seen, there is in the instant case no limit imposed on the wife regarding the appointment of the substitute or substitutes; at most, there is just a simple recommendation to her in connection with their daughter, leaving the wife entirely free to dispose of the property to whomever she wishes. ...

The only limitation is that if the question of relationship happens to arise in connection with the interpretation of a will or instrument, then Section 10 does not apply if the testator died before April 17, 1920, or to an instrument made before that date. ... Riddell, J.A., said this in connection with the question whether a man killed in an accident stood in loco parentis to his sister, on pp. 549-50: Our own Courts do not give much assistance in the enquiry. ... The offices and duties of a parent are infinitely various, some having no connection whatever with making a provision for a child; and it would be most illogical, from the mere exercise of any of such offices or duties by one not the father, to infer an intention in such person to assume also the duty of providing for the child.” ...