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In general his testimony confirmed certain information supplied earlier to the Respondent, in connection with filing a Notice of Objection: The basis of your reassessment is that my intent was solely to move in after the purchase of the property. ... Finally, in connection with this calculation, events showed that there would be a vacancy period to take into account (some three months) on almost any short term lease- a large loss in calculated revenue, with little corresponding reduction in expenses. ...

In this connection, she mentioned the fact that the sellers brought an action for damages, not an action in execution of title. ... Inc., a company which did not exist when the offer of sale of September 29, 1987 was made to a Montreal Trust real estate broker and communicated to Les Experts Conseils Trefor Inc., represented by Roger Tremblay; (b) the purchase offer of December 30, 1986 differed in several respects from the offer of sale of September 29, 1987, in particular as to price, conditions, terms of payment and so on; (c) the offer of sale of September 29, 1987 was not regarded by the parties in question simply as a modified version of the offer of December 30, 1986: on the contrary, both parties concerned considered in their pleadings in connection with the action brought by Marcel Bédard et al. that the offer of December 30, 1986 should be resolved, in the plaintiffs’ view, and was null and void, in the defendants’ view. ...

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, (at 5281-3) (emphases added) Thus, Jackett, P., tying the scope of the privilege in each case to its rationale, clearly extended the solicitor and client privilege (as distinct from the litigation privilege) to communications to or from a third party to the extent that the third party could be seen to be acting as the client’s agent or representative for the purpose of seeking legal advice, and also extended the privilege to “incidental materials that would tend to reveal such communications” and “working papers that came into existence by reason of the desire to obtain a legal opinion or legal assistance”. ... In this regard, it is useful to note these comments of Jackett P., explaining why the privilege should extend to communications to and from the auditor in that case:...think the Court may take judicial knowledge of the fact that corporations of all kinds are continuously faced with problems as to what arrangements are advisable or expedient having regard to the intricacies of the tax laws and that, while huge corporations have staffs of lawyers and accountants of their own through whom they seek advice of counsel learned in such special areas of practice, smaller corporations employ lawyers and accountants in general practice to act for them in obtaining special advice in connection with such matters.... ...

On July 30, 1990, Gilles Lauzon’s office billed the appellant for $285,000 in connection with the sale of the building located at 144 Boulevard de T Hôpital. ... Despite all the testimony which sought to show that this commission was paid not in connection with the sale, but to compensate for the repeated moves that Mr. ...

I am satisfied that reasonable grounds existed for the appellant’s belief that he had severed his connection with the Company as director and secretary-treasurer and concomitantly his responsibility for it when he placed his resignation in the hands of the Company’s president and it was accepted by him. ... Giglio did not sever his connection with Nu-West in October 1991, although he became less “involved” with Nu-West after October 1991. ...

Retirement income fund is defined: “retirement income fund” means an arrangement between a carrier and an annuitant under which, in consideration for the transfer to the carrier of property, the carrier undertakes to pay to the annuitant and, where the annuitant so elects, to the annuitant’s spouse after the annuitant’s death, in each year that begins not later than the first calendar year after the year in which the arrangement was entered into one or more amounts the total of which is not less than the minimum amount under the arrangement for the year, but the amount of any such payment shall not exceed the value of the property held in connection with the arrangement immediately before the time of the payment. ... The appellant seeks to distinguish the Recalma case on the basis that bankers’ acceptances are issued by persons who were not on the reserve and the mutual funds were managed by persons who had no connection with the reserve, whereas here the RRSP and the RRIF were, on the appellant’s characterization, savings accounts and therefore deposit accounts that are located on the reserve in accordance with section 461 of the Bank Act. ...

Accordingly, a deduction cannot be so far removed from its corresponding income stream as to render its connection to the anticipated income tenuous at best. ... Where a loan is made for the purpose of earning income through the payment of dividends, this connection is sufficient to satisfy the purpose requirement of subparagraph 40(2)(g)(ii). ...

Hammond's income in connection with shareholder benefits for the 2015, 2016 and 2017 taxation years. ... MNR (1986), 7 F.T.R. 3 at para. 14, the Federal Court stated that the courts have used the following tests to determine whether the proceeds of the disposition of a property constitute business income or a capital gain: (1) The nature of the property sold; (2) The length of period of ownership; (3) The frequency or number of other similar transactions by the taxpayer; (4) Work expended on or in connection with the property realized; (5) The circumstances that were responsible for the sale of the property; and (6) Motive (the intention at the time of the acquisition). ...

Burnett did nothing in connection with his officer positions as secretary and treasurer of CNCD. ... He responded that: I didn’t make a connection between that and the tiny payroll remittances that were being made every month, supposedly, and that Mr. ...

It is his contention that this subparagraph should only be applied to the business executive who is provided with a company car for his personal use, although he is also expected to use it in connection with his business, but that for someone in the position of defendant it is paragraph 6(1)(a) which should be applied and he should be deemed to be receiving a benefit as a result of being allowed to use the car for personal use when it is not being used for business purposes. ... Instead of basing the charge on the actual use of the car, and the proportion of all the expenses in connection therewith, which required also a determination of the percentage of personal use as compared with business use, paragraphs 6(1)(e) and 6(2)(a) base the charge solely on availability of the car whether it is used or not and apply the percentage formula so calculated solely to capital cost of the car. ...