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Accounts Payable to Affiliated Companies: The evidence in connection with this item establishes that the total of $4,432,000 represents liabilities of the appellant to affiliated companies in the group mentioned earlier, for purchases made in the normal course of trade. ... There are, however, certain differences in the facts of the cases as well as important considerations in connection with the intent and application of the Act which, in my view, afford valid grounds for declining to follow those cases. ... Since the promissory notes representing this indebtedness and the other securities given are for loans of a non-capital nature, it is necessary here to consider the third of the applicable principles mentioned earlier in connection with the interpretation of this statute: “Ill. ...

Since the mortgage interest rate was prime plus two or three percent, the interest rate on Hill Fai’s loan to Chun Fai would have been prime plus four or five percent. [7] The Respondent disputes that Hill Fai charged Chun Fai any interest on the loan. [15]         On top of the $450,000 loan, Hill Fai says it also transferred land to Chun Fai in 1994 and, in connection with this transfer, incurred a receivable from Chun Fai of $110,000. ... Tam testified that no loan agreements or promissory notes were prepared in connection with the debts, and therefore none could be produced in evidence. ... In my view, these financial statements alone do not provide sufficient evidence that Chun Fai owed Hill Fai $110,000 in connection with a land transfer. [40]         I am therefore not satisfied that the debt of $110,000  with respect to "Land" existed. ...

(UBS) entered into an agreement whereby Canaccord was to act exclusively as agent for UBS in connection with a proposed treasury financing for UBS for a minimum of $3,000,000 and a maximum of $6,000,000 raised (the "Offering) by way of a private placement of equity;   d)         in connection with the offering Canaccord agreed to: (1) use best efforts to structure, market and obtain commitments on mutually agreeable terms in respect of the proposed financing of the company; (2) comply with all applicable securities laws in respect of its obligations hereunder (3) advise the company as to the appropriate structure of the financing and assist with the preparation of required documentation; (4) organize meetings between representatives of the company and potential investors; and (5) assist the company in the negotiating and structuring of the final terms of the financing and assist with closing the transaction;   e)         part of the compensation Canaccord received for its services was a Compensation Option to purchase an aggregate of 10% of the Offered Securities issued or issuable at the issue price of the Offering for a period of 24 months;   f)          Canaccord allocated 742,692 UBS Compensation Options, or share purchase warrants (the UBS Warrants), or other consideration received in lieu thereof, to the Appellant on May 28, 1998;   g)         (i) on September 4, 1998 Unique Broadband Systems Inc. (UBS) issued a press release that the Vancouver Stock Exchange had approved the issuance of 2,970,767 share purchase warrants (also referred to as Compensation Options in the above paragraph) to Canaccord in connection with the acquisition of another company by UBS in September 1997 with a stock price of $0.31.               ... n)         Canaccord did not include the value of benefits in respect of warrants in the taxpayer's 1998 T4 slip;   o)         Canaccord exercised the options and immediately sold the acquired shares of UBS upon instructions from the Appellant and throughout the period commencing January 12, 2000 and ending September 26, 2000;   p)         Canaccord charged the Appellant commission on each trade which it executed upon the instructions of the Appellant in connection with the Warrants;   q)         Canaccord paid the net proceeds from the exercise of the options and the disposition of the UBS shares to the Appellant;   r)          Canaccord included the difference between the exercise price of the options and the sale price of the UBS shares as income from employment on the T4 form issued by Canaccord to the Appellant in respect of the 2000 taxation year ...

When the lease of Ord, Wallington for the Montreal premises expired at the end of April they were then planning to sever their connection with them and commence operating their own brokerage house the beginning of May. ... According to her testimony whenever she severed her connections with brokerage firms her clients would follow her as is quite customary in the trade. ... It is never necessary to show a causal connection between an expenditure and a receipt. ...

At 6470 (C.C.C. 102-3) for example the judgment states: absent exceptional circumstances, the provisions of s. 443 of the Criminal Code, which extends to investigations of Criminal Code offences the procedural safeguards the common law required for entries and searches for stolen goods, constitute the minimal prerequisites for reasonable searches and seizures in connection with the investigation of any criminal offence, including possible violations of the Combines Investigation Act. ... Reference was made in this connection to the Supreme Court of Canada case of Wilson v. ... Here we are not of course dealing with an actual search warrant but criteria (2) to (6) are applicable, in particular in connection with No. (5) there has been no complaint whatsoever as to the conduct of the auditor who seized the articles in question, and looking at No. (6), the seizure was only defective since it has now been found to be so, the auditor acting in good faith and pursuant to a section not yet found to be invalid at the time nor do the applicants appear to have suffered any prejudice by being kept out of possession. ...

It is well known that any value added system of taxation is potentially vulnerable to abuse, and that one of the most vulnerable aspects is in connection with claims for input tax credits. ... The Appellant is entitled to the ITCs claimed. [18]     The next ITC claim rejected was in respect of $472.50 paid for GST in connection with accounting services provided by Mary Krauel, C.A. for which she billed $6,750 to Ayerswood. ... It was work in connection with a claim being pursued by Ayersworth against a supplier, but work that the Appellant was obliged to do for Ayersworth under its management agreement. ...

In the hypothetical fact situation in this case, Brazil may tax the gross bond interest income. [6] [17]         The parties disagree, however, on the meaning of the phrase “that part of the income tax…which is appropriate to" which sets the limit of the foreign tax credit that Canada will allow under Article XXII(2). [18]         The appellant maintains that the word "appropriate” in that phrase ordinarily means "specifically fitted or suitable, proper [to or for]” [7] or "especially suitable or compatible: fitting" [8]. [19]         The appellant maintains that by using these definitions, the plain meaning of the upper limit on the tax credit in Article XXII(2) is equal to the Pre-credit Tax that is especially fitted or suitable to the gross interest income which may be taxed in Brazil. [20]         The appellant goes on to say: In the case of a Canadian resident taxpayer whose only Brazil source income is interest income (that is not earned in connection with a permanent establishment of the taxpayer in Brazil) and who has other Canadian source business income, the Canadian source business income is not part of the “income which may be taxed in Brazil”. ... and that: … the amount of Canadian tax that corresponds to the gross interest income arising in Brazil is, based on the ordinary meaning of the terms used in Article XXII(2), the Canadian tax rate multiplied by such Brazilian Bond Interest. [9] (Emphasis added) [21]         The respondent, on the other hand, argues that the word “appropriate” as used in Article XXII(2) contemplates a logical connection between, or apportionment of, the Canadian income tax payable by the taxpayer on the Brazil bond income and the total Canadian income tax paid by the taxpayer on its worldwide income. [22]         The respondent points to the use of the word “correspondant” in the French version of the Treaty, used to translate “appropriate” in Article XXII(2) which The Petit Robert [10] defines as follows: CORRESPONDANT, ANTE, I. ... Qui correspond à qcch. à qqn: qui est en relation de correspondance. [24]         The Noronha’s Legal Dictionary (Portuguese-English English-Portuguese) [12] translates “correspondante” simply as the English adjective “correspondent”. [25]         The respondent maintains that Article XXII(2) requires a logical connection or correlation between “that part of the income tax” and “the income which may be taxed in Brazil.” [26]         In my view, the ordinary meaning of “appropriate” in this case is closer to the definition suggested by the respondent, and refers to a correspondence or logical connection between the part of the Canadian tax to be allowed as a credit and the Brazilian bond income. ...

The position advanced was that the similar facts were not logically relevant in determining the matter in issue in the present appeals nor was there any substantial connection between the actions of the Appellants during the period of time previously audited and the circumstances that are before the Court. [11] [25] It is generally accepted that evidence of similar facts is considered collateral and is generally inadmissible unless there is, as Bull J.A. observed in MacDonald v. ... Ltd.: [12]... a real and substantial nexus or connection between the act or allegation made, whether it be a crime or a fraud (but not, of course, limited to those), and facts relating to previous or subsequent transactions are sought to be given in evidence, then those facts have relevancy and are admissible not only to rebut a defence, such as lack of intent, accident, mens rea or the like, but to prove the fact of the act or allegations made.... ... As I have indicated, the test is relevancy and relevancy depends largely on nexus or connection of the other transactions with the ones in issue- and a strong connection can well be admissible as relevant to the fact of the actus reus.... [26] The question of the admissibility of similar fact evidence was also dealt with by McIntyre J. in Sweitzer v. ...

This is one of those fine line questions between seeking evidence and questions aimed at getting the witness to divulge relevant facts in connection with an allegation. ... Again, I can see some possible relevance, certainly in connection with the penalty issue: this request should be answered.   42.              ... Duan, in connection with his expert opinion in this matter, they should be provided.   49.              ...

Instead they went to people with whom Harold Coombs had a close connection. ... They all had very little connection with the charity, and were not so wealthy that a gift of this nature would be expected. ... Russell had no, or very little, connection with the charity and gave no credible explanation for these very large donations. ...