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Apart from the gathering of raw data, all other work was done in Canada and was substantially of the same nature as that carried out in connection with the Whale and Oldsquaw Projects. ...

Minister of National Revenue, [5] Rouleau J. made reference to: the nature of the property sold; length of period of ownership; frequency of similar transactions; the work expended in connection with the property realized; the circumstances responsible for the sale of the property; the taxpayer’s intention at the time of acquisition of the asset. ...

Separate Reasons for Judgment in connection with the three corporate Appellants (the “Corporate Appeals”) were rendered on June 24, 2021 (2021 TCC 42). [2] This matter addresses costs and considers the written submissions of the parties. ...

. … 225.2 (1) In this section, judge means a judge or a local judge of a superior court of a province or a judge of the Federal Court. (2) Notwithstanding section 225.1, where, on ex parte application by the Minister, a judge is satisfied that there are reasonable grounds to believe that the collection of all or any part of an amount assessed in respect of a taxpayer would be jeopardized by a delay in the collection of that amount, the judge shall, on such terms as the judge considers reasonable in the circumstances, authorize the Minister to take forthwith any of the actions described in paragraphs 225.1(1)(a) to 225.1(1)(g) with respect to the amount. (3) An authorization under subsection 225.2(2) in respect of an amount assessed in respect of a taxpayer may be granted by a judge notwithstanding that a notice of assessment in respect of that amount has not been sent to the taxpayer at or before the time the application is made where the judge is satisfied that the receipt of the notice of assessment by the taxpayer would likely further jeopardize the collection of the amount, and for the purposes of sections 222, 223, 224, 224.1, 224.3 and 225, the amount in respect of which an authorization is so granted shall be deemed to be an amount payable under this Act. (4) Statements contained in an affidavit filed in the context of an application under this section may be based on belief with the grounds therefor. (5) An authorization granted under this section in respect of a taxpayer shall be served by the Minister on the taxpayer within 72 hours after it is granted, except where the judge orders the authorization to be served at some other time specified in the authorization, and, where a notice of assessment has not been sent to the taxpayer at or before the time of the application, the notice of assessment shall be served together with the authorization. (6) For the purposes of subsection 225.2(5), service on a taxpayer shall be effected by (a) personal service on the taxpayer; or (b) service in accordance with directions, if any, of a judge. (7) Where service on a taxpayer cannot reasonably otherwise be effected as and when required under this section, the Minister may, as soon as practicable, apply to a judge for further direction. (8) Where a judge of a court has granted an authorization under this section in respect of a taxpayer, the taxpayer may, on 6 clear days notice to the Deputy Attorney General of Canada, apply to a judge of the court to review the authorization. (9) An application under subsection 225.2(8) shall be made (a) within 30 days from the day on which the authorization was served on the taxpayer in accordance with this section; or (b) within such further time as a judge may allow, on being satisfied that the application was made as soon as practicable. (10) An application under subsection 225.2(8) may, on the application of the taxpayer, be heard in camera, if the taxpayer establishes to the satisfaction of the judge that the circumstances of the case justify in camera proceedings. (11) On an application under subsection 225.2(8), the judge shall determine the question summarily and may confirm, set aside or vary the authorization and make such other order as the judge considers appropriate. (12) Where any question arises as to the course to be followed in connection with anything done or being done under this section and there is no direction in this section with respect thereto, a judge may give such direction with regard thereto as, in the opinion of the judge, is appropriate. (13) No appeal lies from an order of a judge made pursuant to subsection 225.2(11).   ...

(“Happy Valley Farms”) (para. 18) including 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) the motive for selling. ...

.- all amounts received by him in the year as an allowance for personal or living expenses or as an allowance for any other purpose, except (vii.l) reasonable allowances for the use of a motor vehicle received by an employee (other than an employee employed in connection with the selling of property or the negotiating of contracts for the employer) from the employer for travelling in the performance of the duties of the office or employment, The Minister made mention of paragraph 18(1) in the Reply to the Notice of Appeal. ...

In connection with the application he made to the CPTAQ in 1984 for the permit to build his residence, the appellant described his objectives as follows (at p. 2 of Exhibit A-1): [TRANSLATION] Development Project (L506/R3726/T2/BT2) test_linespace (240>217.60) 0.847 0965_4803_4937 We have sufficient resources that will enable us to meet the following schedule: Short term: (0- 2 years) • preparing soil and sowing; ¢ application of soil enhancers and fertilizers; ¢ application of pesticides and herbicides: ° construction of fences. ...

Here, we do not have this intimate connection. The closest reserve, the Dakota Ojibway reserve, was 100 kilometres away from Winnipeg, while the furthest away, the Keewatin reserve, was located so far north that an overnight airplane trip was required to get to Winnipeg. ...

Canadian Investment Fund (CIF) The CIF is intended to identify the dollar value of the pool of property that is considered to be used or held in connection with the Canadian business of the insurer. 4 4In the transcript of his evidence, from pages 106 to 109. 5 55 % management fee x GWLP receivable from GWL of $49,709,601 = $248,548. 6 The interest calculation on a demand note of $124,500,000 issued by GWLP to GWL in December 1988. ...

If that had been the case, a connection by marriage could not have been established between Mr. ...