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Following which, Iacobucci J. added at page 733 (C.T.C. 57): In making this statement, and in proceeding to discuss an interpretation bulletin reference to the "income-earning process" (at pages 189-90 (C.T.C. 301)), Wilson J....was rejecting both the need for a causal connection between a particular expenditure and a particular receipt, and the suggestion that a receipt must arise in the same year as an expenditure is incurred. ... It was in the context of speaking to this "purpose" test that Iacobucci J. rejected both the need for a causal connection between a particular expenditure and a particular receipt and the suggestion that a receipt must arise in the same year as an expenditure is incurred. ... The trial judge erred in relying on the statement made by Iacobucci J. in Symes (where he says that Wilson J. rejected "both the need for a causal connection between a particular expenditure and a particular receipt, and the suggestion that a receipt must arise in the same year as an expenditure is incurred") (Symes, supra, at page 733 (C.T.C. 57; D.T.C. 6013), so as to make it a rule applicable to the case at bar. ...

The Minister may seize a considerable number of documents whose connection with enforcement of the Act may be tenuous. 3. ... Sections 38 and 40 of the Act, as well as section 39 which authorizes a demand for the production of documents, are directed only at documents the contents of which have some connection with the application of tax legislation to taxpayers. ... In this connection they note the difficulties associated with gathering information, the credibility of witnesses, even with the recovery of fees, interest and fines, in view of the risks that the corporate vehicle might be altered or cease to exist. ...

This generally means the ability, through the ownership of shares, to elect the majority of the board of directors (Duha Printers at para. 36). [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 Ltd. v. ... The Tax Court also rejected the submission that the change in shareholders post-IPO was relevant because there likely was no common connection among the public shareholders. [54] The Tax Court went on to conclude that there was no attempt to disguise what rights Matco had and that Matco simply did not have effective control over the Respondent or need such control to make the arrangement work. ... Canada held that “simple ownership of a mathematical majority of shares by a random aggregation of shareholders in a widely held corporation … without a common connection does not constitute de jure control as that term has been defined in the case law.” 11 [106] Subsection 111(5) is part of group of specific rules in subsections 111(4) to (5.3) that limit the carry-forward of non-capital losses, net capital losses, farm losses and unrealized losses on capital, depreciable and eligible capital property owned by the corporation and on doubtful debts. ...

Viscount Simon L.C. stated (at page 339): I find it impossible to adopt the view that a person who (by having the requisite voting power in a company subject to his will and ordering) can make the ultimate decision as to where and how the business of the company shall be carried on, and who thus had in fact control of the company’s affairs, is a person of whom it can be said that he has not in this connexion a controlling interest in the company. [9] After stating that a bare majority is sufficient to vest control, the Lord Chancellor addressed the argument that for certain purposes a 75 per cent shareholder majority was required and that a bare majority, therefore, could not vest full control. ... McGilvery, who collectively owned more than 50 per cent of the shares of Stradwick’s Limited, had at all material times a sufficient common connection as to be in a position to exercise control.... [19] The Court here recognized that any combination of shareholders that can exert majority control are linked by a “sufficient common connection” for the purposes of the de jure test, and therefore, in law, control the corporation. ...

In this latter connection, counsel for the respondent submitted that by virtue of the payments the respondent was ipso facto subrogated to the employee’s claim for wages. ...

Class 8(d) reads: Property not included in Class 2, 7, 9 or 30 that is (d) a tangible capital asset that is not included in another class in this Schedule except: (i) land or any part thereof or any interest therein, (ii) an animal, (iii) a tree shrub, herb or similar growing thing, (iv) a gas well (other than a gas well that is part of the equipment of a farm and from which the gas produced is not sold), (v) a mine, The issue expressed in terms of the factual situation, is whether all pipes and valves located between the inlet and outlet connections of the main pipeline and to and from the compressor station (and metering facilities) are to be treated as integral parts of the “pipeline” or of the compressor station (or the metering facilities), for the purposes of capital cost allowance. ...

  [61]            The same is true in Perrette, when the Quebec Court of Appeal was considering whether subsection 101.1(1) BIA authorized a trustee, in connection with a proposal, to exercise the remedy for recovering preferential payments allowed in bankruptcy matters (ibid., paragraph 29) ...

The Association incurred legal expenses of $1,500,000.00 in connection with these activities. ...

That being so I cannot conceive how those who devised the deceit should now be entitled to say that really the operation of supplying the Iraqis had no real business connection with Canada and to rely on a series of well recognized cases as providing them, as a result of that allegation, with a defence to an assessment from income tax unless the defence is clearly and unmistakably available to them. ...

Paragraph 4 provides, at the outset, that any liability by the Cummings to Domtar accrues only “... in the event that the tenant pays any amounts to the lessor or lessors of the Old Premises in connection with the early vacat- ing by the tenant of the Old Premises...”. ...