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That was too weak a connection to overcome the strong connection between the investment and its off-reserve economic basis. [19]            The investment income in issue in Lewin was paid to an Indian on investment certificates issued by a credit union located on a reserve. ... That is a connection to the reserve but, in my view, a relatively weak one. ... Frazer invested his money in the Royal Bank, his investments became a source of income with no more connection to the reserve than the investment of Ms. ...

No further intervention or supervision was done on its behalf nor were any directions given in connection with its day-to-day operations. ...

The appellant kept money on deposit in Canada which was used in connection with the purchases.There was thus at least some organization of the operation. ...

BETWEEN: BRENT ROCKWOOD       Applicant           - and- THE MINISTER OF NATIONAL REVENUE Respondent     REASONS FOR JUDGMENT SEXTON J.A. [1]                The Applicant claimed unemployment insurance benefits in connection with work performed for companies (the Payors) variously owned by his father, sister, mother, brother-in-law and wife or some of them. [2]                The applicant was denied benefits under the Unemployment Insurance Act because the Minister of National Revenue decided that the Payors and the Applicant were not dealing with each other at arm's length and that there was no employer-employee relationship between them. [3]                The Tax Court Judge set out in detail the assumption made by the Minister which showed that the applicant's position with the Payors was an artificial arrangement designed solely to obtain the maximum unemployment insurance benefits. [4]                The Tax Court Judge held that the onus was on the Applicant to establish that the Minister acted capriciously or arbitrarily and that the Applicant had failed to discharge this onus. ...

His wife incurred interest and carrying costs in connection with loans taken out to finance the transactions. ... The amount of the losses was equal to the interest and carrying charges paid in connection with the loans. [2]                The appellant claimed the losses pursuant to subsection 74.1(1) of the Income Tax Act, R.S.C. 1985, c. 1 (5 th Supp.) ...

Docket: A-36-11 BETWEEN: OPERATION SAVE CANADA TEENAGERS Appellant and MINISTER OF NATIONAL REVENUE (CANADA REVENUE AGENCY) Respondent     Docket: A-37-11 AND BETWEEN:   REVIVAL TIME MINISTRIES INTERNATIONAL Appellant   And   MINISTER OF NATIONAL REVENUE Respondent     REASONS FOR ORDER     Introduction [1]                Operation Save Canada Teenagers (Operation Save) and the Minister of National Revenue (Minister) have each brought a motion in connection with the Minister’s revocation of Operation Save’s registration as a charity (Court File No. ...   [2]                Revival Time Ministries International (Revival Time) and the Minister have brought materially identical motions in connection with the Minister’s revocation of Revival Time’s registration as a charity (Court File No. ...

In particular he stated that: 9     The definition requires that statements or representations must be made, at some time, in connection with the property that is offered for sale. If no statements or representations have ever been made in connection with a property, then that property cannot constitute a tax shelter. ... Accordingly, the existence of statements or representations in connection with a property is a necessary condition to a conclusion that the property constitutes a tax shelter ...

Neither appellant has any real ongoing connection with the United States. [2] As citizens of the United States, the appellants are subject to income tax in that country on their worldwide income, and are subject to annual reporting obligations to the U.S. ... For example, the foreign financial institution is required to determine whether a customer may be subject to FATCA by having regard to several indicia or connections to the United States, such as an address or telephone number, or an “in-care-of” or “hold mail” address as the sole address on file. ... Some of their concerns are listed below. • Affected persons may have very few connections to the United States and the United States may not otherwise know about their existence. • Information will be disclosed about some persons who have no personal connection to the United States. ...

The following passages are from the Court’s reasons: I am not able to accept the argument of applicant’s counsel that because Said audit or examination was not being conducted in applicant’s place of business or where anything was being done in connection with applicant’s business, that said examination and resultant seizure was outside the authority of paragraph 231 (1)(d). ... The Edmonton City Police Station is obviously not a place where any business is carried on or anything is done in connection with any business within the meaning of subsection 231(1). ... On the English version of the section I might be disposed to read these words as qualified by the words “in connection with any business”, but the French version of the section excludes that construction. ...

  [9]                The definition requires that statements or representations must be made, at some time, in connection with the property that is offered for sale. If no statements or representations have ever been made in connection with a property, then that property cannot constitute a tax shelter. ...   [41]            The opening portion of the definition of tax shelter contains a requirement that statements or representations be made in connection with the property. ...