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Later, however, he refused to accept the applicant's evidence of the actual hours spent by him in this connection. [3]                 There thus appears to be an internal inconsistency in the reasons of the Tax Court Judge. ...

Accordingly, he concluded that, as a practical matter, the issue before him was the validity of the 10% penalties that were assessed against the Taxpayer under subsection 163(1) of the Act for 2009 and 2010. [4]                In the Tax Court of Canada, the Taxpayer asserted that he had never worked for, or been paid by, the three companies that issued the T4s to him in respect of the unreported amounts of income, and that he must have been a victim of Social Insurance Number fraud. [5]                The Tax Court Judge considered evidence of connections between the Taxpayer and the three companies that issued the T4s to him. ...

Despite having no connection to those specific cases and, thus, having no standing, the applicant sought reconsideration by the Board of those decisions more than six years after they were first made. ...

However the parties have agreed that the uses made by the Company of the leased reserve land were “related to the production of pulp”, [3] the activity in connection with which the appellants were employed. ...

Hyde, DJ:—For the reasons given by Mr Justice Pratte I would dispose of this application in the manner he suggests. 1 In this connection, it would be necessary to consider the decision of the Privy Council in Attorney General for Canada v Attorney General for Ontario, [1937] AC 355, subsection 91 (2A) of the British North America Act, and Martin Service Station v MNR (SCC, 1976). ...

I think the real question is, was there any inter-connection, any interlacing, any interdependence, any unity at all embracing those two businesses [...]. ... There were also some connections. Minor quantities of scrap metal were acquired from the salvage operations. ... There was no functional connection between the two activities – no interconnection, no interdependence, and no interlacing. ...

In connection with its offer, Falconbridge received fees (Fees) from Diamond Fields totalling $101,541,987. [2] The appellant, Glencore Canada Corporation (Glencore), is a successor to Falconbridge. ... Yonge Eglinton Building Ltd., [1974] 1 F.C. 637; 74 D.T.C. 6180 (FC-AD): “in connection with”; “incidental to”; or “arising from”. ... Accordingly, the Fees were received “in connection with”, or “in the course of”, these activities. ...

As of August 9, 1971, the agreements whereby Socal sold crude at cost to Irvcal [12] and rvcal sold it to Irving Refining Ltd. at its fair market value were executed. [13] As the learned trial judge aptly found at 292 (D.T.C. 6158), they provided for " the metaphysically sequential, if apparently simultaneous, shifts of ownership'at the ship's permanent hose connections at the loading port'. ... The following table compares the modus operandi under the 1957 agreement and the 1971 agreements: The 1957 Agreement The 1971 Agreements a) the respondent submitted an esti a) the respondent submitted the same mate of it annual crude oil requirement estimate, at the same time, to Irvcal, to Socal about three months before which immediately transmitted it to So year end; cal; b) Socal nominated the ships to be b) Socal nominated the ships to be used for carriage of the crude oil; used for carriage of the crude oil; c) the respondent and Socal communi c) the respondent and Socal usually cated as to the scheduling of the ship- communicated through Irvcal as to the ments; scheduling of shipments; communica tions were relayed verbatim by Irvcal; the respondent and Socal sometimes communicated directly; d) the crude oil was loaded in the Mid d) the crude oil was loaded in the Mid dle East on to Socal owned or Socal dle East onto Socal owned or Socal chartered ships for delivery "C.I.F. chartered ships for delivery "C.I.F. ship's permanent hose connection at ship's permanent hose connection at Saint John, New Brunswick"; Saint John, New Brunswick”; e) invoices billing the respondent were e) invoices billing Irvcal were prepared prepared by Socal and sent to the re- by Socal and sent to Irvcal; invoices spondent; billing the respondent were prepared by Irvcal and sent to the respondent; all information needed to adjust the base price was provided by Socal to Irvcal; f) an inspector's report was prepared by f) an inspector's report was prepared by an independent surveyor when the an independent surveyor when the cargo was unloaded at Saint John; ad cargo was unloaded at Saint John; ad justed invoices were based on that re- justed invoices were based on that re port; port; g) all payments for crude oil were made g) all payments for crude oil were made by the respondent to Socal at First Na by the respondent to Irvcal's bank ac tional City Bank in New York. count at First National City Bank in New York; the funds were immediately transferred to Socal's account at the same bank. ... Irvcal, not the [respondent], earned the profits, despite the metaphysically sequential, even if apparently simultaneous, shifts of ownership "at the ship's permanent hose connections at the loading port". ...

Having examined the returns I do not think it can be said that the disclosure by the Minister of the material relied on in making the (3) Subsections (1) and (2) do not apply in respect of criminal proceedings, either by indictment or on summary conviction, under an Act of the Parliament of Canada, or in respect of proceedings relating to the administration or enforcement of this Act. (4) An official or authorized person may, (a) in the course of his duties in connection with the administration or enforcement of this Act, (i) communicate or allow to be communicated to an official or authorized person information obtained by or on behalf of the Minister for the purposes of this Act, and (ii) allow an official or authorized person to inspect or to have access to any book, record, writing, return or other document obtained by or on behalf of the Minister for the purposes of this Act; (b) under prescribed conditions, communicate or allow to be communicated information obtained under this Act, or allow inspection of or access to any written statement furnished under this Act to the government of any province in respect of which information and written statements obtained by the government of the province, for the purpose of a law of the province that imposes a tax similar to the tax imposed under this Act, is communicated or furnished on a reciprocal basis to the Minister; or (c) communicate or allow to be communicated information obtained under this Act, or allow inspection of or access to any book, record, writing, return or other document obtained by or on behalf of the Minister for the purposes of this Act, to or by any person otherwise legally entitled thereto. (5) Notwithstanding anything in this section, the Minister may permit a copy of any book, record, writing, return or other document obtained by him or on his behalf for the purposes of this Act to be given to the person from whom such book, record, writing, return or other document was obtained or the legal representative of such person, or to the agent of such person or of such legal representative authorized in writing in that behalf. (6) An order or direction made in the course of or in connection with any legal proceedings requiring an official or authorized person to give evidence assessment was full save in the sense that the returns were identified as the source of his information on several points and I have no difficulty in conceiving of a number of ways in which the returns, whether admitted in evidence or not, may be of very considerable usefulness to the respondents at the trial in endeavouring to rebut any case put forward by the Minister, if for no other purpose. ... I would add also that, in my view, any question as to the relevancy and admissibility of these documents at trial is a matter to be decided by the judge presiding thereat. 1 41. (1) Subject to the provisions of any other Act and to subsection (2), when a Minister of the Crown certifies to any court by affidavit that a document belongs to a class or contains information which on grounds of a public interest specified in the affidavit should be withheld from production and discovery, the court may examine the document and order its production and discovery to the parties, subject to such restrictions or conditions as it deems appropriate, if it concludes in the circumstances of the case that the public interest in the proper administration of justice outweighs in importance the public interest specified in the affidavit. (2) When a Minister of the Crown certifies to any court by affidavit that the production or discovery of a document or its contents would be injurious to international relations, national defence or security, or to federal-provincial relations, or that it would disclose a confidence of the Queen’s Privy Council for Canada, discovery and production shall be refused without any examination of the document by the court. 2 + 241. (1) Except as authorized by this section, no official or authorized person shall (a) knowingly communicate or knowingly allow to be communicated to any person any information obtained by or on behalf of the Minister for the purposes of this Act, or (b) knowingly allow any person to inspect or to have access to any book, record, writing, return or other document obtained by or on behalf of the Minister for the purposes of this Acct. (2) Notwithstanding any other Act or law, no official or authorized person shall be required, in connection with any legal proceedings, (a) to give evidence relating to any information obtained by or on behalf of the Minister for the purposes of this Act, or (b) to produce any book, record, writing, return or other document obtained by or on behalf of the Minister for the purposes of this Act. ...

Article 1 — Grant of Mining Rights 1.01 Cuisson hereby grants to Gibraltar the sole and exclusive right and authority, subject however to the terms hereof, to prospect, explore, develop and mine the Claims, or any one or more of them, and to transport the ore therefrom to the Gibraltar concentrator, and without restricting the generality of the foregoing, to: (a) develop, mine, work, use, manage, and control the said Claims, and any water, surface, or other rights appurtenant thereto or associated therewith: (b) mine, extract, remove from the Claims, and mill ores and minerals, and use the Claims for ore storage, pit wall slopes, waste dumps, and/or transportation; (c) prepare, or cause to be prepared, the Claims, for production, including removal and disposal of timber and the grubbing and burning of stumps, stripping of overburden, and construction of roads, powerlines, and other services required, in the opinion of Gibraltar, to prepare the Claims for production; (d) erect, construct, maintain, use and operate on the Claims buildings, machinery, plant and equipment; (e) apply for and take in its own name, or in the name of Cuisson, as Gibraltar in its sole discretion decides, permits, licences, leases, easements and rights- of-way, and other rights required in connection with: (i) the said preparation of the Claims for production, (ii) mining, (iii) milling, (iv) transportation, or (v) selling of the products of the Claims; (f) in the name of Cuisson, and as its attorney, and in the sole discretion of Gibraltar, to abandon and restake the Claims or any one or more of them, or to group the Claims, and to charge, assign, mortgage, pledge or encumber: (i) the Claims or any of them, (ii) the machinery or equipment used or to be used to mine and transport the ore and waste from the Claims, (iii) the ore from the said Claims, (iv) the concentrate arising from the said Claims. ... Each party shall maintain a separate status and shall be responsible only for its proportionate share of the risks and costs incurred in connection with the activities contemplated by this Agreement. ... It appears to me that once it is accepted that these amounts represented expenditures by the appellant in connection with its own mining operations, as in my opinion they were, as opposed to mining operations of Cuisson, they would properly appear in the accounts of the appellant’s mining operations, whether as capital or income expenses, and not as mining expenditures in the accounts of Cuisson. ...