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For property to be considered a tax shelter, there must have been statements or representations made in connection with that property, as described in para. ...

In rejecting a submission that the gains realized on donation did not qualify for exemption under s. 39(1)(a)(i.1) because the paintings were acquired on income account, Sexton J.A. found that properties purchased for the purpose of donation are, therefore, not acquired in connection with a 'scheme for profit-making'. ...

Boisvert drew a distinction between the legal and other expenses incurred in connection with issuing the shares and issuing the supplementary letters patent, and found that the latter were not deductible under s. 11(1)(cb)(i). ...

She also rejected a submission that it represented an abuse of that Convention to rely on such treaty exemption where the trust in question had very little connection with Barbados. ...

Canada (Revenue Agenc y), [2010 DTC 5057] 2010 FC 326 wherein a delinquent taxpayer failed to convince the Court that there was any connection between several deaths and illnesses of immediate family members and his inability to pay his taxes. ...

Fisher accepted the determination made by the taxpayer of a bad debt allowance in connection with the transfer of his retail fur business to a corporation controlled by him. ...

Profit- Debt/ receivables infrequent acquisitions of mortgages at a discount occurred as a sideline personal investing activity The taxpayer, a lawyer, who acquired approximately 1 1/2 mortgages per year at a discount out of his personal savings and who made the acquisitions only after he concluded they were safe investments, realized a $700 discount on the mortgage in question for $7,100 as an accretion to capital rather than in connection with an adventure in the nature of trade. ...

Canada, 2010 DTC 5172 [at at 7304], 2010 FCA 280-- summary under Sham Summary Under Tax Topics- General Concepts- Sham trust deed did not reflect the factual expectatons of the settler and trustee A purported Barbados trust that was used in connection with a tax plan to avoid Canadian capital gains tax on the disposition of shares of a corporation was found not to exist at the time of a purported sale of shares by the purported trust given that the settler never intended to lose control of the shares to the Barbados trustee, or of the money resulting from their sale, he did not sign the trust deed until after the sale of the shares to the third party, and the shares were not validly transferred to the trust (and, in fact, at the relevant time, they could not be so transferred because they were subject to the security interest of a third party). ...