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Supplementary letters patent authorizing the amendment to the authorized capital of the company and the creation of the preference shares purportedly issued in connection with the transfer and the section 85 election of the company were not obtained from the Province of Prince Edward Island. ...

(Emphasis added) [56]         Once it is determined that an item is acquired and used in connection with a commercial activity of a GST registrant and that item directly or indirectly contributes to the production of articles or the provision of services that are taxable supplies, then an ITC will be available using a formula in accordance with subsection 141.01(5) of the Act. [57]         While I agree with the Respondent that the primary use of those decks is for the propulsion of the vessels and that they support and are connected, therefore, to exempt services, the evidence was clear and uncontradicted that some portion of those decks is indirectly connected and necessary to BCF’s commercial activities conducted onboard the vessels. ...

He was duly recognized as an expert qualified to give opinion evidence in connection with providing a general background on the coal industry and coal-fired generating facilities. ...

Nor were the companies aware of the contents of the letter until the record was produced in connection with this Application ...

Thus, land used in connection with a building or structure was exempted from the limitation imposed by subsection 18(2). ...

On-Line hereby grants to the Authority a continuing and specific security interest in, and hereby grants, assigns, transfers and sets over to, the Authority all of its right, title and interest in and to the Lease Agreements entered into pursuant to the Leasing Program Agreement and all benefits and advantages to be derived from the Lease Agreements, including, without limitation, any payment derived therefrom and the benefit of any and all representations, warranties, conditions, terms and covenants on the part of all other parties to the Lease Agreements therein or implied or expressed by law in relation thereto with full power and authority to enforce performance of such terms or covenants, or to demand, sue for and collect damages in connection with any misrepresentation, breach of warranty or breach of covenant either in the name of and as agent for On‑Line, or in the name of the Authority, to have and to hold for the Authority until all monies under and all obligations of the respective lessees under the Lease Agreements have been fully paid and fulfilled.   ...

M.N.R. summarized the principles that apply with respect to disclosure to accountants as follows:   Applying these principles, as I understand them, to materials prepared by accountants, in a general way, it seems to me   (a)     that no communication, statement or other material made or prepared by an accountant as such for a business man falls within the privilege unless it was prepared by the accountant as a result of a request by the business man's lawyer to be used in connection with litigation, existing or apprehended; and   (b)     that, where an accountant is used as a representative, or one of a group of representatives, for the purpose of placing a factual situation or a problem before a lawyer to obtain legal advice or legal assistance, the fact that he is an accountant, or that he uses his knowledge and skill as an accountant in carrying out such task, does not make the communications that he makes, or participates in making, as such a representative, any the less communications from the principal, who is the client, to the lawyer; and similarly, communications received by such a representative from a lawyer whose advice has been so sought are none the less communications from the lawyer to the client. [19]   [72]         Counsel for the Appellant argued that the solicitor-client privilege extended to communications with PWC Australia on the basis that PWC Australia’s input was necessary to the provision of legal advice by counsel. ...

The statute is explicit: 5. (1) * * * (a) The Minister * * * may make such an allowance * * * as he may deem just and fair * * * The general language of sec. 66, conferring the exclusive jurisdiction upon the Exchequer Court, is circumscribed and limited by such phrases as "subject to the provisions of this Act * * *" and "determine all questions that may arise in connection with any assessment * * *". ...

Evidence was given of a specific difficulty which the Company had experienced in connection with an export order which it had accepted on the assurance that it would get the necessary lead from the Canadian supplier and a loss which it had sustained through the failure of the Canadian supplier to deliver it. ...

Two English decisions are worth noting in this connection. Firstly, there is the case of Mersey Docks and Harbour Board v Proctor, [1923] AC 253 at 258-9. ...