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The tax deduction he is claiming in this Court applies to the 1994 and 1995 taxation years. [4]                 It was established that the appellant rendered his services in connection with employment and that the UN is an international organization to which the regulations apply. ...

In particular, the objectors should be informed that a law firm which had carriage of some of the lead cases has withdrawn and that his own appeals are now lead cases; and (c)                 he is entitled to a copy of the transcripts of the examinations for discovery of the Crown that were held in connection with other appeals that have now settled. [10]            I do not agree that the motions judge erred in rejecting these submissions, and substantially for the reasons that the motions judge gave. ...

As part of this service, the appellant is responsible for appeals to the Tax Court in circumstances where the Minister of National Revenue has denied a DTC claim. [2] An employee of the appellant who is not a lawyer appeared before the Tax Court in connection with these DTC appeals. ...

Furthermore, he allegedly misunderstood the object of the appellant’s application (appellant’s memorandum, at paras. 97–105); refused to interpret the Children’s Special Allowances Act, S.C. 1992, c. 48; provided a poor description of the interaction between the different statutory schemes involved; disregarded the fact that there was no assessment appealable to the TCC for certain members of the group; and failed to explain why the Federal Court could not grant declaratory relief or issue an injunction against the CRA in connection with the class action in the event that the Court was satisfied that the CRA was acting illegally, as the appellant claimed (appellant’s memorandum, at paras. 106–141). [6] The stumbling block with respect to all these arguments is the fact that only the TCC has jurisdiction to rule on the alleged illegality that underlies the class action, in all its aspects. ...

Collier, J. granted the application, basically, for the following reasons: In this present litigation, the plaintiff is not seeking to get confidential information and material gathered by the Minister in the course of general income tax informa- Subsections 241(1), (2) and (3) read as follows: 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 Act. (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. (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. tion, procedures, investigations and matters of that kind. ...

As a result I assumed the unnamed persons were Italian citizens, although with a Swiss connection, and that they wished investments out of Italy. ...

E‑15, in connection with properties she purchased in 2016 and 2017. [3] Under the Excise Tax Act, a taxpayer who wishes to object to a reassessment must file a notice of objection in “the prescribed form and manner” within 90 days of the mailing of the notice of reassessment: Excise Tax Act, s. 301(1.1). ...

Bykov appeals from these judgments. [2] The main issue in this appeal is whether the Tax Court erred in disallowing additional deductions for motor vehicle expenses incurred by the appellant in connection with employment. ...

They import such meanings as "in relation to", "with reference to" or "in connection with". ... "Proceedings" in section 32 must have some connection to a cause of action. Whether they are court action or statutory collection procedures, they have some connection to a cause of action. ...

Although no such distinction was made, it seems clear that with respect to non-resident corporations, the obligation to file could only extend to those that had some connection with Canada. To construe the provision as applying in the absence of any connection with Canada would give it a reach that could not have been intended. To this extent, I respectfully disagree with the Tax Court Judge when she says (Reasons, para. 15):   Prior to these amendments, all corporations were required to file income tax returns in Canada, regardless of whether they were resident in Canada or had any connection to Canada. …   [Emphasis added] [24]            Subsection 150(1) was amended in 1998 to expressly require corporations to file a tax return when, in a given taxation year, they reside in Canada, carry on business in Canada, have a taxable capital gain or dispose of Canadian taxable property. ...