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Accordingly, Transport Couture could exercise de facto control over ML1 and ML2 although the de jure control lay elsewhere. [15]      After a lengthy analysis of the facts surrounding the operations of the corporations in question, and relying principally on their economic dependence on Transport Couture, the operational control exercised over each of them by Transport Couture and the family connection between the shareholders of the three corporations the trial judge concluded there was such control by Transport Couture over ML1 and ML2 (reasons, paragraphs 34 to 38). ...

Weaver ceased being actively involved with SRP in November of 1998, he coordinated the activities of SRP in connection with the warranties. ...

The judgment under appeal sets out a very detailed account of the activities in connection with the development of the real estate in the area south of Wascana Lake adjacent to the City of Regina. ...

I do not find that high degree of negligence in connection with the misstatements of business income. ...

(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. c) la réalisation de fournitures, sauf des fournitures exonérées, d'immeubles appartenant à la personne, y compris les actes qu'elle accomplit dans le cadre ou à l'occasion des fournitures. ...

See also s. 139(1)(ae) of the Income Tax Act which includes as "personal and living expenses" and therefore not deductible for tax purposes, the expenses of properties maintained by the taxpayer for his own use and benefit, and not maintained in connection with a business carried on for profit or with a reasonable expectation of profit. ...

The failure to properly understand and apply the law as it applies to capital gains in share transactions The appellant’s submission in this connection starts from the proposition that the acquisition of shares is "presumptively an investment". ...

In addition to its reliance on the Canadian Bank of Commerce case the appellant contended, in support of its interpretation of subsection 231(3), that information of the kind sought in the present case with respect to a whole class of persons could only be properly obtained by an information return provided for by regulation made by the Governor in Council pursuant to paragraph 221 (1)(d), which reads: 221. (1) The Governor in Council may make regulations (d) requiring any class of persons to make information returns respecting any class of information required in connection with assessments under this Act, The provisions of Part Il of the Regulations (sections 200 and following) show that what is generally contemplated by an information return is a report of a payment or receipt that is taxable. ...

In Consolidated Textiles v MNR, [1947] Ex CR 77 at 81; [1947] CTC 63, I expressed the opinion that it was not a condition of the deductibility of a disbursement or expense that it should result in any particular income or that any income should be traceable to it and that it was never necessary to show a casual connection between an expenditure and a receipt. ...

I note that Ms Telfer was legally represented in this appeal and had been assisted by different counsel in her dealings with the CRA in connection with her subsection 220(3.1) request. ...