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A demand made in respect of a non-resident, with no apparent connection to Canada, would not proceed under this provision. ... The applicants claimed to have no connection with two corporations, one of which was incorporated in the British Virgin Islands. ... If the information is located outside of Canada, and there is a connection between the entities, then the Applicant may request the information, rather than its production, under section 231.1 (as seen in Miller). ...

Rather, I will address objections as needed when analysing the evidence in connection with the substantive issues being adjudicated and when considering the impact of potentially relevant and material evidence to which an objection has been raised. ... Frohnhoefer’s evidence and exhibit references in connection with these operations is in 1986. This timing does not predate 1985, when the C-Tow Marks were in use by C-Tow’s predecessors in title. [120] I also agree with C-Tow’s response to this evidence, that it is insufficient to demonstrate use of the Sea Tow Marks in connection with services provided in Canada. ...

Thus, CPR claims in this action an order for repayment to CPR of the amounts of tax wrongfully collected in connection with the purchases of fuel.  It also seeks a declaration that CRA is not entitled to collect fuel taxes on fuel purchased, consumed or used in connection with the exempt main line of CPR.   ... In respect of the LCT, CPR also seeks a declaration that the Crown is not entitled to collect tax imposed under Part l of the ITA on income earned by CPR in connection with the operation of its railway as originally defined in the CPR Act.  ...

  [13]            No tribunal record was produced by the Respondent in connection with this application for judicial review. ...   [20]            In External Technical Interpretation 2000-0023275 (E) (the “Technical Interpretation”), dated September 22, 2000, the CRA advised the DFO of the following: Treatment of Licence Retirement   A fishing license held in connection with a fishing business is an eligible capital property in respect of the fishing business. ... In December 2003, in connection with a number of fish harvesters, the CRA offered to treat half of their AGLRP payments as non-taxable, and the other half as capital gains. ...

I have cited the above extracts at some length not only in connection with the question of admissibility on which in my view there can be no doubt, but also with respect to the effect of an allocation made in a valid written instrument after negotiations at arm’s length between the vendors and purchasers with nothing to indicate that the apportionment reached was a sham or a subterfuge. ... Accordingly, the provisions of subsection 101(2) of the Act which reads as follows: Where, on an appeal by the Minister, other than by way of cross-appeal, from a decision of the Tax Review Board, the amount of tax that is in controversy does not exceed $2,500, the court, in delivering judgment disposing of the appeal, shall order the Minister to pay all reasonable and proper costs of the taxpayer in connection therewith. ... As all the actions were joined for hearing on common evidence only one set of costs shall be allowed to the Crown on the dismissal of the appeals of Messrs Wise, Pollock, Burnstein and Sokoloff and one set of costs allowed to Dr Claude Leclerc and Mr Lemay in connection with the successful appeals by the Crown in their cases. 1 Louis Burnstein was not one of the vendors, the fourth vendor along with Messrs Pollock, Sokiloff and Wise being the executors of the estatae of the late Emanuel Herschman but no issue was raised respecting this. ...

Copps in a personal capacity, but is in connection with the promulgation of a management plan for the Park and a decision to deny the Plaintiff a business licence for the summer operation of its Mount Norquay gondola lift. [10]            The basic proposition is that a Minister of the Crown may not be sued in his or her representative capacity, nor may he or she be sued personally, unless the actions are done in a personal capacity. ... Copps are all expressly or impliedly to her actions, in the capacity of Minister, in connection with promulgation of the 1997 Management Plan which, as I say, takes the same view of summer gondola operation as the Long Range Management Plan it replaced. ... Zinkan, Lee and Fisher arise, for the most part, or perhaps entirely, in connection with the promulgation of the 1997 Management Plan. ...

With respect to Normand and Stéphane Descôteaux’s criminal past, the applicants explained that this factor was irrelevant because they have no connection to the applicants.  And as for the family connections between the applicants in docket T-1084-08, they are allegedly insufficient to establish a reasonable apprehension that the transactions are irregular or that the applicants in this case would squander their assets. [22]   Finally, the applicants argue that Her Majesty breached her duty to disclose to the Court all relevant facts when submitting the ex parte application and that the affidavits supporting this application contained insufficient, inaccurate or out-of-context allegations. ... Directions (12) Where any question arises as to the course to be followed in connection with anything done or being done under this section and there is no direction in this section with respect thereto, a judge may give such direction with regard thereto as, in the opinion of the judge, is appropriate. ...

  (2) Without limiting the generality of subsection (1), for greater certainty, the Federal Court has jurisdiction with respect to all of the following:   (a) any claim with respect to title, possession or ownership of a ship or any part interest therein or with respect to the proceeds of sale of a ship or any part interest therein;   (b) any question arising between co-owners of a ship with respect to possession, employment or earnings of a ship;   (c) any claim in respect of a mortgage or hypothecation of, or charge on, a ship or any part interest therein or any charge in the nature of bottomry or respondentia for which a ship or part interest therein or cargo was made security;   (d) any claim for damage or for loss of life or personal injury caused by a ship either in collision or otherwise;   (e) any claim for damage sustained by, or for loss of, a ship including, without restricting the generality of the foregoing, damage to or loss of the cargo or equipment of, or any property in or on or being loaded on or off, a ship;   (f) any claim arising out of an agreement relating to the carriage of goods on a ship under a through bill of lading, or in respect of which a through bill of lading is intended to be issued, for loss or damage to goods occurring at any time or place during transit;   (g) any claim for loss of life or personal injury occurring in connection with the operation of a ship including, without restricting the generality of the foregoing, any claim for loss of life or personal injury sustained in consequence of any defect in a ship or in her apparel or equipment, or of the wrongful act, neglect or default of the owners, charterers or persons in possession or control of a ship or of the master or crew thereof or of any other person for whose wrongful acts, neglects or defaults the owners, charterers or persons in possession or control of the ship are responsible, being an act, neglect or default in the management of the ship, in the loading, carriage or discharge of goods on, in or from the ship or in the embarkation, carriage or disembarkation of persons on, in or from the ship;   (h) any claim for loss of or damage to goods carried in or on a ship including, without restricting the generality of the foregoing, loss of or damage to passengers’ baggage or personal effects;   (i) any claim arising out of any agreement relating to the carriage of goods in or on a ship or to the use or hire of a ship whether by charter party or otherwise;   (j) any claim for salvage including, without restricting the generality of the foregoing, claims for salvage of life, cargo, equipment or other property of, from or by an aircraft to the same extent and in the same manner as if the aircraft were a ship;   (k) any claim for towage in respect of a ship or of an aircraft while the aircraft is water-borne;     (l) any claim for pilotage in respect of a ship or of an aircraft while the aircraft is water-borne;   (m) any claim in respect of goods, materials or services wherever supplied to a ship for the operation or maintenance of the ship, including, without restricting the generality of the foregoing, claims in respect of stevedoring and lighterage;   (n) any claim arising out of a contract relating to the construction, repair or equipping of a ship;   (o) any claim by a master, officer or member of the crew of a ship for wages, money, property or other remuneration or benefits arising out of his or her employment;       (p) any claim by a master, charterer or agent of a ship or shipowner in respect of disbursements, or by a shipper in respect of advances, made on account of a ship;   (q) any claim in respect of general average contribution;   (r) any claim arising out of or in connection with a contract of marine insurance; and   (s) any claim for dock charges, harbour dues or canal tolls including, without restricting the generality of the foregoing, charges for the use of facilities supplied in connection therewith ...

Accordingly, even if the applicant’s notice of assessment indicated that he had no balance due, he nevertheless could have had tax payable for the year that was remitted by way of source withholdings. [43]            In this connection, the Respondent relies upon three decisions, two of the Tax Court: Valdis v R, [2001] 1 CTC 2827 at para 17 [Valdis] and Ruffolo v R, [2000] 3 CTC 142 at paras 4-5 [Ruffolo], and one of the Federal Court of Appeal: Interior Savings Credit Union v R, 2007 FCA 151 at para 22. ... I do so for completeness’ sake and having had the benefit of reviewing the record together with oral and written submissions on the point. [49]            In this connection, the evidence is that even before CRA advised him there was an over-contribution, the Applicant had already withdrawn the over-contribution, as seen from the following chronology taken from paragraph 14 above: I.                    ... In this connection, I note that the Minister is obliged by subsection 152(1) of the ITA to assess taxes “with all due dispatch”. ...

The Applicant then sent the Investigator an email on March 26, 2018, with records prepared by him on the files he worked on at GAC. [8]   Materially on the issue of procedural fairness, the Investigator interviewed two GAC officers in connection with certain case management tracking documents maintained by GAC on ATIP files worked on by the Applicant in 2013. ... The general principles regarding the content of the duty of fairness in this connection are set out in Re: Sound, where the Federal Court of Appeal states: [54]   However, agencies must ensure that, if they obtain information from third parties, they do not thereby jeopardize parties’ participatory rights: to know and to comment on material relevant to the decision; to have notice of the grounds on which the decision may be based; and to have an opportunity to make representations accordingly. ... [Emphasis added] [33]   In this connection and before the hearing, the following direction was sent to the parties alerting counsel of the importance of this issue: The Court has questions regarding the 131 pages of documents in the Supplementary Certificate dated 29 November, 2018, stated to be contained in the “Commission’s investigation file” in respect of the Applicant’s complaint. ...