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  [47]            This case is extremely complex, and the ramifications and the connections between each actor are very difficult to establish given the many real estate transactions.   ...   [66]            The respondents submit that although there are family connections between them, this reality cannot lead the Minister to believe that said transactions are irregular or create doubt of such magnitude that it would warrant reasonable apprehension that the respondents would squander their assets. ...

  [56]            When read as a whole, these provisions show that there is a connection between the abuse of authority and the Commission’s responsibility to appoint a person who meets the essential qualifications; however, this connection is not clearly established, and an analysis of the PSEA is necessary to understand the obligations of the manager and the assessment board ...

In his 1992 and 1993 tax returns, he claimed tax deductions of $9,600 and $12,000 in connection with those shares. ... Finally, he stated that other interrelated files were to be submitted shortly by counsel in connection with a collective request for the cancellation of interest. ...

Canada (National Revenue), 2013 FC 1219 Date: 2013 1205 Dockets: T-437-12 T-967-12   Citation: 2013 FC 1219 Ottawa, Ontario, December 5, 2013 PRESENT:    The Honourable Madam Justice Mactavish Docket: T-437-12   BETWEEN: GENERAL MOTORS OF CANADA LIMITED   Applicant And MINISTER OF NATIONAL REVENUE   Respondent Docket: T-967-12   AND BETWEEN: RICHARD SZYMCZYK   Applicant And MINISTER OF NATIONAL REVENUE   Respondent   REASONS FOR JUDGMENT AND JUDGMENT [1]                For over 25 years, General Motors of Canada Limited (GMCL) calculated the value of the taxable benefits received by certain of its senior employees in connection with the use of company cars in accordance with a formula that had been agreed to by Revenue Canada Taxation in 1982 (“the 1982 formula”) ... Szymczyk had received in connection with his use of company cars, the Minister’s conduct cannot serve to relieve him of his statutory obligation to pay: Webster v. ...

Lewis Chipman [14] Further, all the work in connection with this fund is to be performed by the Royal Trust Company as trustee. ... There is nothing to be performed in connection with this trust by the “Burns Memorial Trust”, nor is there a body or entity which could be described as an institution styled the “Burns Memorial Trust”. ...

The other sections of the 1936 Act referred to in section 22 thereof are concerned with matters of an entirely different nature, but, reading section 22 of the 1936 Act in connection with the whole of section 19 of the Income War Tax Act as enacted in 1936 and with the other provisions of the Income War Tax Act, I conclude that the "income" mentioned in section 22 refers (as applicable to section 11) to the income of the taxpayer. ... Therefore, as the distribution in connection with the sale of the Security Loan & Savings Company did not take place until 1937, section 22 of the Act of 1936 should be disregarded for the purposes of this appeal. ...

Section 231 reads in part as follows:       231. (1)  Any person thereunto authorized by the Minister, for any purpose related to the administration or enforcement of this Act, may, at all reasonable times, enter into any premises or place where any business is carried on or any property is kept or anything is done in connection with any business or any books or records are or should be kept, and   (a)  audit or examine the books and records and any account, voucher, letter, telegram or other document which relates or may relate to the information that is or should be in the books or records or the amount of tax payable under this Act,   (b)  examine property described by an inventory or any property, process or matter an examination of which may, in his opinion, assist him in determining the accuracy of an inventory or in ascertaining the information that is or should be in the books or records or the amount of any tax payable under this Act,   (c)  require the owner or manager of the property or business and any other person on the premises or place to give him all reasonable assistance with his audit or examination and to answer all proper questions relating to the audit or examination either orally or, if he so requires, in writing, on oath or by statutory declaration and, for that purpose, require  the owner or manager to attend at the premises or place with him, and   (d)  if, during the course of an audit or examination, it appears to him that there has been a violation of this Act or a regulation, seize and take away any of the documents, books, records, papers or things that may be required as evidence as to the violation of any provision of this Act or a regulation ... The court applied the reasoning in Belgoma and ruled that an individual's privacy interests in connection with this type of inspection were much less than those in Hunter.       ...

In this connection s. 3(2)(c)(i) refers to the Income Tax Act, which has long provided in s. 251(1): first, that "related persons" are deemed not to be dealing with each other at arm's length when they enter into a contract, "related persons" being taken to mean (according to s. 251(2)):      251. (2) For the purposes of this Act, "related persons", or persons related to each other, are      (a)      individuals connected by blood relationship, marriage or adoption;      (b)      a corporation and          (i)      a person who controls the corporation, if it is controlled by one person,          (ii)      a person who is a member of a related group that controls the corporation, or          (iii)      any person related to a person described in subparagraph (i) or (ii); and     ...      251. (2) Aux fins de la présente loi, des "personnes liées" ou des personnes liées entre elles, sont      a)      des particuliers unis par les liens du sang, du mariage ou de l'adoption;      b)      une corporation et          (i)      une personne qui contrôle la corporation si cette dernière est contrôlée par une personne,          (ii)      une personne qui est membre d'un groupe lié qui contrôle la corporation, ou          (iii)      toute personne liée à une personne visée au sous-alinéa (1) ou (ii);         ... and, second, that "unrelated" persons may occasionally be regarded as not dealing at arm's length in view of the special conditions in which their dealings took place. 4 So the legislative technique is different from what it was previously, in that the exclusion does not apply to the spouses directly but to all persons who are "related"; however, because of the presumption established by s. 251(2)(a) of the Income Tax Act, the exclusion relating to the spouses remains the same, unless an exception to the peremptory nature of the presumption is adopted. ... However, in a recent judgment this Court undertook to reject that approach, and I take the liberty of citing what I then wrote in this connection in the reasons submitted for the Court: 9          The Act requires the Minister to make a determination based on his own conviction drawn from a review of the file. ...

Paragraph 8(1)(f) sets forth deductions that may be made by an employee whose employment is in connection with the selling of property or the negotiating of contracts. ... (f) where the taxpayer was employed in the year in connection with the selling of property or negotiating of contracts for the taxpayer's employer, and (i) [...] ...

If this had not been the case, US and Foreign Investors in Blackstone Capital Partners would have incurred Canadian tax in connection with that sale. The Co-Investors have also incurred, undoubtedly, significant legal costs in connection with the establishment of the revised structure. [26]   Alta Canada carried out the development of its Working Interest in the Duvernay Formation in Northern Alberta (the Kaybob area of Alberta). ...