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Furthermore, the connection between the appellants and the Reserve is mitigated by the fact that the employment relationships between the appellants and NLS or OI were created merely for the purpose of obtaining a paragraph 87(1)(b) exemption. ... In Monias, the Federal Court of Appeal attached almost no significance to the location of branches of the banks from which the employer paid salaries and at which the employees’ accounts were credited, saying (at paragraph 57):   Where employees receive their employment income has little, if any, logical connection with the policy underlying section 87 ...   [146]      In the absence of any special circumstances that would tie the appellants’ work to a specific reserve, and in the absence of evidence of a significant connection between their work and the Six Nations Reserve or any other reserve, there is no basis for concluding that the taxation of their employment income from NLS or OI would result in the erosion of their entitlement to property they held as Indians on a reserve ...

NM I's proportionate share of revenues was subject to a further annual adjustment based on the cumulative expenditures made by NM I and Vidatron in connection with the marketing program. ... NM II's proportionate share of revenues was subject to a further annual adjustment based on the cumulative expenditures made by NM II and Vidatron in connection with the marketing program. ... Jones said that she provided no instructions to Grant in connection with his evaluation preparation and that Grant had come to her telling her what he needed in order to do so. ...

Colbran's attention so that he is fully aware of the steps being taken by the Landlord. [18]     He then produced a letter from Murray Holmes to 95 stating that he had searched their files and could not find any record of having acted for the Appellant in connection with the Cheesecake Café. [19]     The Appellant produced a copy of a letter dated March 29, 2000 to Tillyard & Partners, Inc. from The Cheesecake Cafe not bearing a signature but bearing the typed name of R.F. ... It is noted that Beeson appeared as the Respondent's only witness, having appeared as the result of being served with a subpoena so to do. [111] It is clear, from the evidence of both the Appellant and Beeson, that the Appellant was employed by the Beeson group to perform operational services in connection with the Victoria Cheesecake Café. [112] I accept the Appellant's evidence that when he signed the subscription for shares of 95 and signed the CONSENT TO ACT AS A DIRECTOR, he expressly directed Ross, the lawyer who produced the "shelf" company not to use those documents until he had become a resident of British Columbia and until other conditions specified by him were fulfilled. ... In that company Wheeliker signed statements of particulars in connection with a Royal Bank of Canada account as "director" and the Agreement Re: Operation of Account as "director" of the company. ...

The only reimbursement by CKUA for expenses incurred by Burton or other account executives was in connection with travel outside their designated sales territory or in the instance where Burton was reimbursed the cost of a civic luncheon because the General Manager (GM) of CKUA was unavailable and had requested her to attend on his behalf and represent CKUA. ... Burton used the computer at the CKUA office in connection with making her sales but that was never a requirement of her contract. ... Her expenses in connection with attending a luncheon- at which she substituted for the GM of CKUA- were paid by the appellant. ...

The distinction was pointed out by Davies J in connection with similar words used in s.26AAA(4) of the Act in Barnsdall v. ... The Commissioner is required to be satisfied not merely of a connection between a taxpayer and the person to whom the taxpayer transferred, but also of the fact that they were not dealing with each other at arm's length. A finding as to a connection between the parties is simply a step in the course of reasoning and will not be determinative unless it leads to the ultimate conclusion. ...

A number of cases were cited in connection with the arm's length issue, including Peter Cundill & Associates Limited v. ... Moreover, the lengthy reasons of the Judge below fail to disclose any misconduct anterior to the litigation that could be imputed to the Commission and be considered as sufficiently serious and as having a close enough connection with the litigation to warrant such an award. ... (c) a payment of a dividend contrary to section 42,... are jointly and severally liable to restore to the corporation any amounts so distributed or paid and not otherwise recovered by the corporation.... 118(4) Recovery A director liable under subsection (2) is entitled to apply to a court for an order compelling a shareholder or other recipient to pay or deliver to the director any money or property that was paid or distributed to the shareholder or other recipient contrary to section 34, 35, 36, 41, 42, 44, 124, 190 or 241. 118(5) Order of court In connection with an application under subsection (4) a court may, if it is satisfied that it is equitable to do so, (a) order a shareholder or other recipient to pay or deliver to a director any money or property that was paid or distributed to the shareholder or other recipient contrary to section 34, 35, 36, 41, 42, 44, 124, 190 or 241;... ...

There was a large amount of contradictory evidence in connection with these matters heard in this appeal and the credibility of many of the witnesses are in issue, although it is safe to say that many of the witnesses had credibility problems on at least some of the issues but not all. ... She testified she used this account to make down payments on her Collingwood condominium, live on after she left 145, deposit rent cheques from 145 in connection with her ownership of 89 Shorncliffe and deposit the proceeds of her house sale into as well as draw the funds to pay off her mortgage on the Collingwood condo. ... A tremendous amount of evidence was heard in connection with these other assumptions dealing with the underlying basis for the reassessment against the Appellant and although it is not necessary for me to explore them further in order to arrive at the conclusion I have arrived at, I do believe addressing some of these issues will further support my conclusion as well as highlight the issues of credibility that were raised in this matter.   ...

Martin to inform him that she would not provide the contracts, which were in Calgary in connection with litigation there. ... Canada 18, that there are three essential elements to the tort of conspiracy: an agreement to cause damage to another person, a concerted action carried out in pursuance of that agreement and actual economic damage resulting from a direct causal connection to that action. [79]      In Canada Cement LaFarge Ltd. v. ... I have referred to this earlier but in this connection there simply was not evidence before me of the prejudice claimed by the plaintiffs. ...

  [18]            Prothonotary Aalto also found that s.7 of the Charter was not engaged because no causal connection was pleaded between the impugned Government economic policies and actions and an infringement of the right to life, liberty and security of the person. ...   [59]            The Defendants argue that the Prothonotary was right to conclude that there is no causal connection pleaded connecting the impugned Government economic policies and actions to a breach of s. 7. Nor are there any “evidentiary facts” pleaded, whether “real or intangible” (see Operation Dismantle Inc, above, at para 78), that could establish such a causal connection, and no real possibility of establishing such facts. ...

Its purpose is instead to set up an administrative mechanism for the collection of taxes.   2.The Minister may seize a considerable number of documents whose connection with enforcement of the Act may be tenuous.   3.The Act allows for searches at the premises of third parties who are not the subject of an investigation and who may have been in compliance with the Act.   4.Certain searches took place at the respondents' private homes, not their commercial establishments.   5.Searches involve a greater intrusion into individual privacy than a mere demand for production of documents.   ... Sections 38 and 40 of the Act, as well as s. 39 which authorizes a demand for the production of documents, are directed only at documents the contents of which have some connection with the application of tax legislation to taxpayers.  ... In this connection they note the difficulties associated with gathering information, the credibility of witnesses, even with the recovery of fees, interest and fines, in view of the risks that the corporate vehicle might be altered or cease to exist.  ...