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In June 2018, the Tribunal found that there was a direct causal connection between the discrimination and the loss of that position. ... Hughes to an Intelligence Marine Analyst position at the PM-04 level, yet also found that the causal connection between TC’s discrimination and the lost wages and benefits had been severed in May 2011. ... In other words, I am unable to see the rational connection between these factors and the cut-off date. ...

As this appeal comes within subsection 178(2) of the Income Tax Act as it stood at the time this appeal was launched, the Minister is ordered to pay all reasonable and proper costs of the taxpayer in connection with this appeal. ...

Defendant states plaintiff wishes to delete it in order to avoid questioning in connection therewith. ...

Consequent upon that finding, the relevant provisions of the statute are subsection 5(1), and thereafter paragraph 115(2)(c) and subparagraph 115(2)(e)(i); 5. (1) Subject to this Part, a taxpayer’s income for a taxation year from an office or employment is the salary, wages and other remuneration including gratuities, received by him in the year. 115. (2) Where, in a taxation year, a non-resident person was (c) an individual who had, in any previous year, ceased to be resident in Canada and who was, in the taxation year, in receipt of remuneration in respect of an office or employment that was paid to him directly or indirectly by a person resident in Canada, (e) for the purposes of subpararaph (l)(a)(v), the aggregate determined under this paragraph in respect of the non-resident person is the aggregate of (i) any remuneration in respect of an office or employment that was paid to him directly or indirectly by a person resident in Canada and was received by the non-resident person in the year, except to the extent that such remuneration is attributable to the duties of an office or employment performed by him in a country other than Canada and (A) is subject to an income or profits tax imposed by the government of a country other than Canada, or (B) is paid in connection with the selling of property, the negotiating of contracts or the rendering of services for his employer, or a foreign affiliate of his employer, or any other person with whom his employer does not deal at arm’s length, in the ordinary course of a business carried on by his employer, and that foreign affiliate or that person, In a very persuasive presentation, counsel for the plaintiff argued that since Dr Jarlan had ceased to become a resident of Canada before these payments were made to him, it was open to me to conclude that they escaped the classification as income and could be treated as royalties, as contemplated by subpara- graph 212(l)(d)(i): 212 (1) Every non-resident person shall pay an income tax of 25% on every amount that a person resident in Canada pays or credits, or is deemed by Part I to pay or credit, to him as, on account or in lieu of payment of, or in satisfaction of, (d) rent, royalty or a similar payment, including, but not so as to restrict the generality of the foregoing, any payment (i) for the use of or for the right to use in Canada any property, invention, trade name, patent, trade mark, design or model, plan, secret formula, process or other thing whatever, I find, however, that the Dauphinee case is directly on point with the sole exception that Dr Dauphinee always remained a resident of Canada. ...

Mr Justice Addy had already concluded the stock option issue against Greiner when he referred to Greiner’s position in connection with another issue which need not be considered here. ...

There is a very heavy onus on a lawyer who seeks to claim a deduction over and above the expenses applicable to his regular office, in connection with the use of a room in his home as an office study. ...

:—This is an appeal by the Crown from a decision of the Tax Court of Canada dated March 19, 1990, wherein it was held that moneys received by the defendant from his employer, in connection with his relocation from Edmonton to Toronto, was: not to be included in the computation of his income for the 1985 taxation year. ...

I set out both subsections: 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. ...

It states that all the income of an Indian will be exempt from income tax when:      "      THE EMPLOYER IS RESIDENT ON A RESERVE; AND               "      THE EMPLOYER IS:                      -      AN INDIAN BAND WHICH HAS A RESERVE, OR A TRIBAL COUNCIL REPRESENTING ONE OR MORE INDIAN BANDS WHICH HAVE RESERVES, OR                      -      AN INDIAN ORGANIZATION CONTROLLED BY ONE OR MORE SUCH BANDS OR TRIBAL COUNCILS, IF THE ORGANIZATION IS DEDICATED EXCLUSIVELY TO THE SOCIAL, CULTURAL, EDUCATIONAL, OR ECONOMIC DEVELOPMENT OF INDIANS WHO FOR THE MOST PART LIVE ON RESERVES; AND               "      THE DUTIES OF THE EMPLOYMENT ARE IN CONNECTION WITH THE EMPLOYER'S NON-COMMERCIAL ACTIVITIES CARRIED ON EXCLUSIVELY FOR THE BENEFIT OF INDIANS WHO FOR THE MOST PART LIVE ON RESERVES;... ...

Subsection 241.2 stipulates that notwithstanding any other Act of Parliament or other law, no official shall be required in connection with any legal proceeding to produce evidence relating to any taxpayer information. [8]      Third, to prepare and produce generalized and sanitized sample case material would go beyond what the Federal Court of Appeal required in Québec Port Terminals Inc. v. ...