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At the same time, the Plaintiff and his counsel agree to abide by any confidentiality order that might be issued by this Court in connection with the disclosure of the requested information and that such compliance would include non-disclosure of the taxpayer's identity to the Plaintiff, personally. [19]      As for the arguments against disclosure on the basis of section 241(3) of the Act, the Plaintiff submits that this action falls squarely within the exception recognized in section 241(3)(b), being a proceeding for the administration and enforcement of the Act. ... This situation is contemplated by rule 152 of the Rules. [23]      The Defendants' argument on a putative change in position by the Plaintiff, is rejected. [24]      As for the second ground of objection, that is the statutory and common law protection against disclosure of confidential taxpayer information, these arguments rest on the question whether this action relates to the "administration and enforcement of the Act" as these words are used in section 241(3)(b) of the Act. [25]      Section 241 of the Income Tax Act provides as follows: 241. (1) Except as authorized by this section, no official shall (a) knowingly provide, or knowingly allow to be provided, to any person any taxpayer information; (b) knowingly allow any person to have access to any taxpayer information; or (c) knowingly use any taxpayer information otherwise than in the course of the administration or enforcement of this Act, the Canada Pension Plan, the Unemployment Insurance Act or the Employment Insurance Act or for the purpose for which it was provided under this section. (2) Notwithstanding any other Act of Parliament or other law, no official shall be required, in connection with any legal proceedings, to give or produce evidence relating to any taxpayer information. (3) Subsections 241(1) and 241(2) do not apply in respect of (a)      criminal proceedings, either by indictment or on summary conviction, that have been commenced by the laying of an information or the preferring of an indictment, under an Act of Parliament; or (b)      any legal proceedings relating to the administration or enforcement of this Act, the Canada Pension Plan, the Unemployment Insurance Act or the Employment Insurance Act or any other Act of Parliament or law of a province that provides for the imposition or collection of a tax or duty. 241. (1) Sauf autorisation prévue au présent article, il est interdit à un fonctionnaire: a) de fournir sciemment à quiconque un renseignement confidentiel ou d'en permettre sciemment la prestation; b) de permettre sciemment à quiconque d'avoir accès à un renseignement confidentiel; c) d'utiliser sciemment un renseignement confidentiel en dehors du cadre de l'application ou de l'exécution de la présente loi, du Régime de pensions du Canada, de la Loi sur l'assurance-chômage ou de la Loi sur l'assurance-emploi, ou à une autre fin que celle pour laquelle il a été fourni en application du présent article. (2) Malgré toute autre loi ou règle de droit, nul fonctionnaire ne peut être requis, dans le cadre d'une procédure judiciaire, de témoigner, ou de produire quoi que ce soit, relativement à un renseignement confidentiel. (3) Les paragraphes (1) et (2) ne s'appliquent: a) ni aux poursuites criminelles, sur déclaration de culpabilité par procédure sommaire ou sur acte d'accusation, engagées par le dépôt d'une dénonciation ou d'un acte d'accusation, en vertu d'une loi fédérale; b) ni aux procédures judiciaires ayant trait à l'application ou à l'exécution de la présente loi, du Régime de pensions du Canada, de la Loi sur l'assurance-chômage ou de la Loi sur l'assurance-emploi ou de toute autre loi fédérale ou provinciale qui prévoit l'imposition ou la perception d'un impôt, d'une taxe ou d'un droit. [26]      For present purposes, sections 241(3)(b) is the critical section. ...

The tugs range from 39 to 142 ft. in length, and from 440 to 5,750 in horsepower and carry from 2 to 9 crew-members. [4]                               From January 1988 to December 1988, which is the relevant time period, the plaintiff purchased diesel fuel in Canada in connection with its business ... It was not our intention to eliminate it in connection with diesel fuel used for transportation.... ...

Additionally, as regards the selling price balance of $1,459,437.39, corresponding to the plaintiffs" hypothecary obligations in connection with the loans made to them for construction of the buildings in question, the evidence further disclosed that they were in fact assumed by Cytro to the plaintiffs" benefit. ... The result of doing so was to accept as the gross selling price of the units the aggregate prices agreed to by their purchasers less the cost of construction financed by way of first mortgage. [18]      In the case at bar, I consider that the circumstances justified the Minister in changing his mind, which he may generally do from one taxation year to another, and considering that no amount could have been regarded as reasonable in respect of the 1971 taxation year for purposes of a reserve within the meaning of s. 85B(1)(d) of the Act, 1 for all the following reasons: "      the balance of the selling price on the plaintiffs' property at December 31, 1971, $1,093,467.52, corresponded exactly to the balance of the plaintiffs' hypothecary debts on the same property which were expressly assumed by the subsequent purchaser Cytro; "      the selling price balances owed the plaintiffs, namely $230,000 and $200,000, when they sold their property on August 1, 1962 were paid to them in full before December 31, 1971; "      between August 1, 1962, the date their property was sold, and December 31, 1971, the end of the fiscal year in question, the plaintiffs, still holding obligations assumed to them by the purchasers Sutton and Charlton, and still bound to their own hypothecary creditors, had in fact agreed that their hypothecary obligations would be paid in full by a subsequent purchaser of their property; "      the plaintiffs in fact benefited before December 31, 1971 from the full profit from the sale, $678,272, in view of the amounts from their hypothecary loans in question, the cash payment of $330,280.81 on the day of the sale and the repayment of the balances of $230,000 and $200,000 owed to them by the purchasers of their property; "      after the sale of their property, as they never had to pay their hypothecary creditors directly, the latter"s rights having been entirely assumed and observed by a subsequent purchaser of the property in question, the plaintiffs were not required after 1971 to lay out any sum in connection with the property and its related hypothecs. [19]      For all these reasons, the appeals cannot be allowed and the action of each of the plaintiffs is dismissed. ...

In this connection, the case of The Queen v. Melford Developments Inc., [1982] C.T.C. 330; 82 D.T.C. 6281 was referred to. ... The question is not that, but whether the collateral legislative action in connection with the Income Tax Act has the effect of amending the 1956 statute. ...

He was ultimately convicted of fraud in connection with these activities, and funds seized by the police were released to charities pursuant to a restitution order. ... Zins makes the following submissions in connection with this request: 10.       ...

(6) what is the quality of the connection with Canada: is it more substantial than that which exists with any other country?   ... (f)        What is the quality of the connection with Canada: is it more substantial than that which exists with any other country?   ...

In other words, such a challenge, in order to be properly before the Court, must be brought in connection with some form of administrative action being contested so as to trigger this Court’s jurisdiction.  ... [15]            I take this finding of the Federal Court of Appeal to mean that a litigant cannot bring a “stand-alone” constitutional challenge by way of a judicial review application absent any type of connection with some actual conduct triggering his or her right to bring a judicial review application and engaging, as a result, the Court’s jurisdiction to consider the matter.  ...

Carroll testified about the affidavit of service that he had sworn on June 14, 2017, in connection with service of the Show Cause Order upon the Respondents. ... She testified that, according to records obtained from the Corporate Affairs Registry for the Province of New Brunswick, the personal Respondent is the sole shareholder and director of the corporate Respondent. [19]   In connection with the income tax audit, the Moncton office of the CRA sent letters dated July 6, 2016, called an “Audit Confirmation Letter”, to each of the Respondents, asking for certain documents and banking records including income tax returns and schedules, financial statements, personal investment statements and personal banking documents. ...

Justice Simpson concluded that the presumption of receipt had not been rebutted and, consequently, dismissed the application for judicial review. [25]   In Wu v Canada (Citizenship and Immigration), 2018 FC 554 [Wu], an immigration officer requested in a letter sent by e-mail that the applicant attend an interview in connection with her application for permanent residence. ... In allowing the application, Justice Gascon found there was no evidence to reasonably determine that the refusal decision had been sent on either July 14, 2016 or November 30, 2016. [27]   In Lu v Canada (Citizenship and Immigration), 2018 FC 1149, the applicants failed to respond to a procedural fairness letter allegedly sent to them via e-mail in connection with their application for permanent residence. ...

Zuniga’s persistent threats and connections with criminal organizations. ... Zuniga’s violent past, criminal connections, and continued threats against the Applicant. ...