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He says he transferred the monies to accommodate his daughter and he believed that she did not have any connection with any alleged wrongdoing on the part of O’Brien. ...

The section was enacted as a measure designed to thwart the use of offshore investment funds which permitted taxpayers resident in Canada a complete escape from or indefinite deferral of tax on passive income. [1] Subsection 94.1(1) reads in part: 94.1 (1) Where in a taxation year a taxpayer, other than a non-resident-owned investment corporation, holds or has an interest in property (in this section referred to as an “offshore investment fund property’’) (a) that is a share of the capital stock of, an interest in, or a debt of, a nonresident entity (other than a controlled foreign affiliate of the taxpayer or a prescribed non-resident entity) or an interest in or a right or option to acquire such a share, interest or debt, and (b) that may reasonably be considered to derive its value, directly or indirectly, primarily from portfolio investments of that or any other nonresident entity in (i) shares of the capital stock of one or more corporations, (ii) indebtedness or annuities, (iii) interests in One or more corporations, trusts, partnerships, organizations, funds or entities, (iv) commodities, (v) real estate, (vi) Canadian or foreign resource properties, (vii) currency of a country other than Canada, (viii) rights or options to acquire or dispose of any of the foregoing, or (ix) any combination of the foregoing, and it may reasonably be concluded, having regard to all the circumstances, including (c) the nature, organization and operation of any non-resident entity and the form of, and the terms and conditions governing, the taxpayer’s interest in, Or connection with, any non-resident entity, (d) the extent to which any income, profits and gains that may reasonably be considered to be earned or accrued, whether directly or indirectly, for the benefit of any non-resident entity are subject to an income or profits tax that is significantly less than the income tax that would be applicable to such income, profits and gains if they were earned directly by the taxpayer, and (e) the extent to which the income, profits and gains of any non-resident entity for any fiscal period are distributed in that or the immediately following fiscal period, that one of the main reasons for the taxpayer acquiring, holding or having the interest in such property was to derive a benefit from portfolio investments in assets described in any of subparagraphs (b)(i) to (ix) in such manner that the taxes, if any, on the income, profits and gains from such assets for any particular year are significantly less than the tax that would have been applicable under this Part if such income, profits and gains had been earned directly by the taxpayer,... ...

They had been incurred in connection with the claim for maintenance upon the divorce. ...

In or around 1959 the Tahsis Company approached the Indian Agent for British Columbia to discuss the possibility of buying or leasing the Reserve in connection with the construction of a proposed pulp mill. ...

In addition, he had never paid his spouse any interest or principal in connection with the $27,800. ...

And... the appellant’s document... which is attached to the Aubin affidavit, which sets out that Smith Kline’s review of the Dyson report in connection with pressure on its transfer price discloses that this report prepared by the Canadian government showed third party prices for the years 1981 to 1985 ranging from $288 down to $69 a kilo.... ...

Paragraphs 6 to 9, inclusive, of the Reply to the Notice of Appeal read: 6 In reassessing the Appellant for the 1992 taxation year, the Minister of National Revenue (the “Minister”) reduced the claim for employment expenses by $4,735.00, from $4,960.00 to $225.00, as follows: Item Claimed Allowed Disallowed Entertainment for Clients $ 596.00 nil $ 596.00 Meals 2,184.00 nil 2,184.00 Parking 225.00 225.00 nil Gloves, Cleats, Miscellaneous $1,955.00 nil 1,955.00 Football Gear Total $4,960.00 $225.00 $4,735.00 7 In so reassessing the Appellant, the Minister made the following assumptions of fact: (a) at all material times to the period under appeal, the Appellant was employed as a football player by the Edmonton Eskimo Football Club (hereinafter referred to as the “Employer”); (b) the Appellant was required to travel for 11 road games during the 1992 taxation year; (c) in respect of the away games referred to in paragraph 7(b) supra, the Appellant was away for no more that 33 days in the 1992 taxation year; (d) during the 1992 taxation year, the Appellant was in receipt of a travel allowance in respect of away game meals from the Employer in the amount of $1,100.00; (e) the allowance referred to in paragraph 7(d) supra was a reasonable allowance for travel expenses within the meaning of subparagraph 6(b)(viii) of the Income Tax Act (the “Act”); (f) the Appellant included the allowance referred to in paragraph 7(d) supra into income in completing his return for the 1992 taxation year; (g) expenses claimed for meals in the amount of $2,184.00 were not reasonable in the circumstances; (h) gloves, cleats and miscellaneous football gear claimed in the amount of $1,955.00 were not supplies that were consumed directly in the performance of the duties of office or employment; (i) during the 1992 taxation year the Appellant: 1. was not employed in connection with the selling of property or negotiating of contracts for the Em ployer; and ii. was not remunerated in whole or in part by com missions or other similar amounts fixed by refer ence to the volume of sales made or the contracts negotiated; (j) expenses claimed in the amount of $4,735.00 that were dis allowed were not proven to have been incurred. ...

They had been incurred in connection with the claim for maintenance upon the divorce. ...

The amount a taxpayer receives from his employer as an allowance is included in his or her income unless that allowance falls within the exceptions listed in paragraph 6(1)(b) or subsection 81(3.1) of the Act or is excluded from income under subsection 6(6). [6] Subparagraph 6(1)(b)(v) allows reasonable allowances for travelling expenses received by an employee from his employer in respect of a period when he was employed in connection with the selling of property or negotiating contracts for his employer. ...

The appellant submits that the expenses paid by Roca in connection with the suppliers and contractors referred to in the preceding paragraph were therefore as follows: Supplier/contractor Amounts paid Groupe A. ...