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It seems the only examples of direct supervision appear to be that management assigned a specific project to the Worker and briefed the Worker on what had to be done and the client expectations, approval of the overall plan and budget estimate created by the Worker, that the Worker had to get approval of any expenses over $2000 and the Worker’s statement that she reported to Drew Black on a daily basis, with no specific details in connection with same. ... Furthermore, ownership and supply of equipment must not be confused with ownership and supply of work instruments. [45]          In On Masse above, in a situation where the Worker was provided use of the appellant’s computer and software Webb J. stated in par. 13 that:   “ He needed to use the Appellant’s computer system and software to integrate his work with the work of the other individuals who were working on the film.” [46]          In my view the provision of those tools by the Appellant was just that; equipment necessary for the integration of work of the Worker with the Appellant, its staff and the Clients of the Appellant and was a necessity in order for the services to be performed, and practically speaking, in respect of the software and two way radio connection at least, only providable by the Appellant. ...

  [48]     However, the main problem with respect to these wire transfers is the lack of existence of a link or connection between the transfers through Sindi Financial or family/friends and the Vialink bank deposits. ... When he finally did provide the names of those individuals, with their telephone numbers, that had gifted/loaned him money, he did not go the step further and supply exact dates of receipts of these funds or the connection to the deposits to the Vialink account. ...

  [5]      The Appellant argued that it did not claim any ITCs for 1169 because these ITCs were in fact in connection with another construction which occurred concurrently with the construction of 1169 (Transcript, page 19). ...   [30]     As I understand the Respondent’s submissions, with respect to the income tax issues in connection to properties 3139 and 160, reliance is placed on section 69 of the Act to include in the Appellant’s income the proceeds of disposition of both these properties at FMV as established on resale by the Nowaks. ...

This section states:   288. (1) Inspections  – An authorized person may, at all reasonable times, for any purpose related to the administration or enforcement of this Part, inspect, audit or examine the documents, property or processes of a person that may be relevant in determining the obligations of that or any other person under this Part or the amount of any rebate or refund to which that or any other person is entitled and, for those purposes, the authorized person may (a) subject to subsection (2), enter any premises or place where any business or commercial activity is carried on, any property is kept, anything is done in connection with any business or commercial activity or any documents are or should be kept; and (b) require the owner or manager of the property, business or commercial activity and any other person on the premises or in the place to give to the authorized person all reasonable assistance and to answer all proper questions relating to the administration or enforcement of this Part and, for that purpose, require the owner or manager to attend at the premises or place with the authorized person ... Desjardins) may also enter a place where a business (that of the Caisse), or commercial activity (that of the Caisse) is carried on, or property is kept (for example, the money Vert-Dure deposited at the Caisse), anything is done in connection with a [16] business (that of the Caisse or Vert-Dure) or a [17] commercial activity (that of the Caisse or Vert-Dure)  or any [18] documents are or should be (for example, a copy of the document confirming the loan by the Caisse to Vert-Dure). ...

  [6]      The assessment is based on the building exchange deed, dated November 19, 2002, between the Appellant and the Comité de Promotion Industrielle de la Ville de Richmond ("CPIR"), a non-profit organization. [7]      Prior to the exchange, the Appellant owned a building formerly used in connection with the operations of H.  ... Earlier, in connection with clause 6, you used the expression "better safe than sorry", is that right?   ...

Work expended on or in connection with the property realized. If effort is put into bringing the property into a more marketable condition during the ownership of the taxpayer or if special efforts are made to find or attract purchasers (such as the opening of an office or advertising) there is some evidence of dealing in the property.   5. ... The Queen, 78 D.T.C. 6281 (F.C.A.), the Chief Justice of the Federal Court stated at 6285 that the term "secondary intention":  ... does no more than refer to a practical approach for determining certain questions that arise in connection with "trading cases" but there is no principle of law that is represented by this tag. ...

He did not necessarily have any drinks in connection with these transactions. ... [TRANSLATION]   1 — 1997   Photocopies of cheques provided to Revenu Québec, totalling $48,786.08, in connection with undeposited DSLs that were included in the $378,753.10 in total deposits.   ...

.- (1) In section 121, this Part and Schedules V to X, "commercial activity" of a person means: (a)    a business carried on by the person (other than a business carried on without a reasonable expectation of profit by an individual, a personal trust or a partnership, all of the members of which are individuals), except to the extent to which the business involves the making of exempt supplies by the person; (b)    an adventure or concern of the person in the nature of trade (other than an adventure or concern engaged in without a reasonable expectation of profit by an individual, a personal trust or a partnership, all of the members of which are individuals), except to the extent to which the adventure or concern involves the making of exempt supplies by the person; and (c)     the making of a supply (other than an exempt supply) by the person of real property of the person, including anything done by the person in the course of or in connection with the making of the supply; "exempt supply" means a supply included in Schedule V; "financial institution", at any time, means a person who is at that time a financial institution under section 149; "financial instrument" means (a) a debt security, (b) an equity security, (c) an insurance policy, (d) an interest in a partnership, a trust or the estate of a deceased individual, or any right in respect of such an interest, (e) a precious metal, (f) an option or a contract for the future supply of a commodity, where the option or contract is traded on a recognized commodity exchange, (g) a prescribed instrument, (h) a guarantee, an acceptance or an indemnity in respect of anything described in paragraph (a), (b), (d), (e) or (g), or (i) an option or a contract for the future supply of money or anything described in any of paragraphs (a) to (h); "financial service " means.[..] ... It is not logical to conclude that the same services rendered in connection with the issuance of insurance policies to Canadian beneficiaries would become zero-rated merely because the Appellant decided to have a part of the risk borne by its foreign subsidiary. [39]     In my opinion, this would run counter to Parliament's intent. ...

From 1990 to 1995, the Partnership recorded expenses in connection with the project being fees billed by Pruefer in excess of $11 million (the "Expenses"). ... He also attempted to obtain certain Canadian Tire property though that property deal never concluded. [37]     Apart from pursuing the lawsuit from 1993 to 1996, there was little evidence of other activity in connection with the Multi-Use Facility Project until 1997. ...

(admitted) g)          In connection with the audit conducted for the period from April 1, 1996, to June 30, 2000, the Appellant was unable to establish, using documentary exhibits, that the motor vehicle had been used exclusively for his commercial activities. ... (no knowledge) u)          The Appellant had claimed input tax credits for expenditures that had no connection to his commercial activities. ...