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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. [91]         Business is defined in subsection 123(1) as follows: “business” includes a profession, calling, trade, manufacture or undertaking of any kind whatever, whether the activity or undertaking is engaged in for profit, and any activity engaged in on a regular or continuous basis that involves the supply of property by way of lease, licence or similar arrangement, but does not include an office or employment. [92]         Under the GST Act, a person’s business is broader than the person’s commercial activity. ...

In the statement of claim, $155,000,000 was claimed as damages for alleged breaches of acquisition agreements as follows: damages of $50 million for breach of warranty in respect of the Software and breach of covenant to provide certain services in connection with, among other things, "the support, training, maintenance, development, enhancement and promotion of the [Software]", damages of $50 million "for breach of certain collateral agreements", damages of $50 million for "fraudulent or negligent misrepresentation", as well as exemplary and punitive damages of $5 million. ... Apart from a clear decision to pursue a criminal investigation, no one factor is necessarily determinative in and of itself, but courts must assess the totality of the circumstances, and make a determination as to whether the inquiry or question in issue engages the adversarial relationship between the state and the individual 94         In this connection, the trial judge will look at all factors, including but not limited to such questions as: (a)         Did the authorities have reasonable grounds to lay charges? ...

Identity of issue may therefore compensate for the lack of physical identity of object where the close connection that links the two proceedings to each other is such that the judge deciding the issue the first time was able to anticipate the consequence in respect of which it is raised a second time. [80]     Since the object of a decision is the recognition of a right, it is normal that the scope of "the authority of a final judgment" can be determined by consulting the judgment itself. ... A professional liability suit was brought against the appellant, a notary, in connection with a legal opinion given to the respondents. ...

"tax shelter" means any property (including, for greater certainty, any right to income) in respect of which it can reasonably be considered, having regard to statements or representations made or proposed to be made in connection with the property, that, i f a person were to acquire an interest in the property, at the end of a particular taxation year that ends within 4 years after the date on which the interest is acquired,      (a)        the total of all amounts each of which is   (i)  an amount, or a loss in the case of a partnership interest, represented to be deductible in computing income in respect of the interest in the property (including, where the property is a right to income, an amount or loss in respect of that right that is represented to be deductible) and expected to be incurred by or allocated to the person for that particular taxation year, or   (ii)  any other amount represented to be deductible in computing income or taxable income in respect of the interest in the property and expected to be incurred by or allocated to the person for the particular year or any preceding taxation year, other than any amount included in computing a loss described in subparagraph (i),   would equal or exceed   (b)        the amount, if any, by which   (i) the cost to the person of the interest in the property at the end of the taxation year,   would exceed   (ii) the total of all amounts each of which is the amount of any prescribed benefit that is expected to be received or enjoyed directly or indirectly in respect of the interest in the property, by the person or another person with whom the person does not deal at arm's length  ...   ... The language that was used, the numerous descriptions, and certain connections with communications giants suggested that there might be some embryonic research, but the numerous inconsistencies and the explanations that were outlandish, to say the least, certainly do not support a finding that Télématique was engaged in serious SR&ED work. ...

The History and Purpose of Workers' Compensation Legislation in Canada 123     The disposition of this appeal requires not only a sensitivity to the true nature of the paramountcy doctrine, but also an appreciation of the history and purpose of workers' compensation legislation. 124     Workers' compensation legislation creates a "no fault" system of benefits whereby injured workers are guaranteed compensation in connection with their injuries. ... In this connection, the Workers' Compensation Board of British Columbia points out that the B.C. legislation does not include an explicit recognition of set-off, but still the B.C. courts appear to have read it according to the general principles of restitution. 176     The second ground for set-off independent of s. 133(3) arises from the contractual relationship between Metal Fab and Husky. ...

Furthermore, Wilma McClurg co-signed with the respondent a personal guarantee to the International Harvester Company, the supplier of the company, with respect to a $500,000 debenture in connection with the business affairs of Northland Trucks.  ...

The question that arises therefore is whether this expense was incurred in the year within the meaning of paragraph 18(1)(a). [25]       In connection with paragraph 18(1)(a), the courts have found that an expense is not incurred in the year unless there is a legal obligation to pay an amount. ...

Therefore, his connection between tax and land can easily be reconciled with the Treaty which gave Indians the option between communal reserves or individual severalty allotments, both of which would be exempt from taxation. ...

  (2)  The Minister shall not accept for registration for the purposes of this Act any retirement savings plan unless, in the Minister’s opinion, it complies with the following conditions:   (a)  the plan does not provide for the payment of any benefit before maturity except   (i)    a refund of premiums, and   (ii)    a payment to the annuitant;   (b)  the plan does not provide for the payment of any benefit after maturity except   (i)    by way of retirement income to the annuitant,   (ii)    to the annuitant in full or partial commutation of retirement income under the plan, and   (iii)   in respect of a commutation referred to in paragraph (c.2);   (b.1)  the plan does not provide for a payment to the annuitant of a retirement income except by way of equal annual or more frequent periodic payments until such time as there is a payment in full or partial commutation of the retirement income and, where that commutation is partial, equal annual or more frequent periodic payments thereafter;   (b.2)  the plan does not provide for periodic payments in a year under an annuity after the death of the first annuitant, the total of which exceeds the total of the payments under the annuity in a year before that death;   (b.3)  the plan does not provide for the payment of any premium after maturity;   (b.4)  the plan does not provide for maturity after the end of the year in which the annuitant attains 69 years of age;   (c)   the plan provides that retirement income under the plan may not be assigned in whole or in part;   (c.1)   notwithstanding paragraph (a), the plan permits the payment of an amount to a taxpayer where the amount is paid to reduce the amount of tax otherwise payable under Part X.1 by the taxpayer;   (c.2)   the plan requires the commutation of each annuity payable thereunder that would otherwise become payable to a person other than an annuitant under the plan;   (c.3)   the plan, where it involves a depositary, includes provisions stipulating that   (i)      the depositary has no right of offset as regards the property held under the plan in connection with any debt or obligation owing to the depositary, and   (ii)     the property held under the plan cannot be pledged, assigned or in any way alienated as security for a loan or for any purpose other than that of providing for the annuitant, commencing at maturity, a retirement income;   (c. 4)        the plan requires that no advantage, other than   (i)         a benefit,   (i.1)      an amount described in paragraph (a) or (c) of the definition “benefit” in subsection (1),   (ii)        the payment or allocation of any amount to the plan by the issuer,   (iii)       an advantage from life insurance in effect on December 31, 1981, or   (iv)       an advantage derived from the provision of administrative or investment services in respect of the plan,   that is conditional in any way on the existence of the plan may be extended to the annuitant or to a person with whom the annuitant was not dealing at arm's length; and   (d)  the plan in all other respects complies with regulations of the Governor in Council made on the recommendation of the Minister of Finance ...

However, the interpretation sought by the respondent is considerably more restricted because it would require a connection to income in years prior to sale.  ...