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The taxpayer ultimately pleaded guilty to trafficking charges but, in connection with sentencing, asserted that his involvement was quite limited and that he did not share in the profits. ...

In rejecting Roofmart’s reliance on the statement in Hydro-Québec that "[w]hen the group is generic and has no connection to the ITA, and information can be requested outside of the scope of the ITA (such as identifying the business clients of a public utility) there is no longer any limit on the fishing expedition," Rennie JA stated (at para 37) that this “passage is not a legal test but analysis of whether, on the facts of that case, there was an ‘ascertainable group’ and whether the information was required for the purposes of verifying compliance,” and that ”the suggestion in the reasons that the information sought was available through other means and therefore could not be obtained through a UPR is inconsistent with this Court’s jurisprudence, and ought not to be followed.” ...

Before so concluding, she also noted (at para. 45): In order for multiple shareholders to collectively exercise de jure control of a corporation, there must be a sufficient common connection between them, such as in a voting agreement, an agreement to act in concert, or business or family relationships (Silicon Graphics...). ...

In connection with its appeal of the CRA denial of these rebate claims, CIBC brought a motion for its appeal to be allowed on the basis that the substance of the supply was already determined in the 2009 Decision. ...

., “in relation to”, “with reference to”, or “in connection with”) the Minister’s decision to issue or confirm the NITR: Nowegijick at 39. ...

In connection with a subsequent audit, CRA obtained a waiver, but only respecting capital gains. ...