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Kwawukumey testified he was experiencing similar difficulties with Revenue Canada in connection with the Child Tax Benefit as with Ontario Health in connection with his application for O.H.I.P. ...

On this second issue, the parties proceeded principally on the basis of an Agreed Statement as to Facts which statement reads as follows: AGREED STATEMENT AS TO FACTS The Appellant and the Respondent do hereby agree with each other in connection with the truth and accuracy of the following facts and statements: 1. ... He refers further to what are known as the oppression provisions in the said B.C.A.S., namely: 234(1) A complainant may apply to a court for an order under this section. (2) If, upon an application under subsection (1), the court is satisfied that in respect of a corporation or any of its affiliates: (a) any act or omission of the corporation or any of its affiliates affects a result; (b) the business or affairs of the corporation or any of its affiliates are or have been carried on or conducted in a manner; or (c) the powers of the directors of the corporation or any of its affiliates are or have been exercised in a manner; that is oppressive or unfairly prejudicial to or that unfairly disregards the interests of any security holder, creditor, director or officer, the court may make an order to rectify the matters complained of. (3) In connection with an application under this section, the court may make any interim or final order it thinks fit including, without limiting the generality of the foregoing: (a) an order restraining the conduct complained of; (b) an order appointing a receiver or receiver-manager; (c) an order to regulate a corporation's affairs by amending the articles or bylaws or creating or amending a unanimous shareholder agreement; (d) an order directing an issue or exchange of securities; (e) an order appointing directors in place of or in addition to all or any of the directors in office; (f) an order directing a corporation, subject to subsection (6), or any other person, to purchase securities of a security holder; (g) an order directing a corporation, subject to subsection (6), or any other person, to pay to a security holder any part of the moneys paid by him for securities; (h) an order varying or setting aside a transaction or contract to which a corporation is a party and compensating the corporation or any other party to the transaction or contract; (i) an order requiring a corporation, within a time specified by the court, to produce to the court or an interested person financial statements in the form required by section 149 or an accounting in such other form as the court may determine; (j) an order compensating an aggrieved person; (k) an order directing rectification of the registers or other records of a corporation under section 236; (l) an order liquidating and dissolving the corporation; (m) an order directing an investigation under Division XVII to be made; (n) an order requiring the trial of any issue. (4) If an order made under this section directs amendment of the articles or bylaws of a corporation: (a) the directors shall forthwith comply with subsection (4) of section 185; and (b) no other amendment to the articles or bylaws shall be made without the consent of the court, until a court otherwise orders. (5) A shareholder is not entitled to dissent under section 184 if an amendment to the articles is effected under this section. (6) A corporation shall not make a payment to a shareholder under clause (f) or (g) of subsection (3) of there are reasonable grounds for believing that: (a) the corporation is or would after that payment be unable to pay its liabilities as they become due; or (b) the realizable value of the corporation's assets would thereby be less than the aggregate of its liabilities. (7) An applicant under this section may apply in the alternative for an order under section 207. ...

Where a person has severed his connection with the corporation of which he is a director, such action relieves the person of vicarious liability for the corporation's default in remitting deductions at source. ... I am satisfied that reasonable grounds existed for the appellant's belief that he had severed his connection with the Company as director and secretary-treasurer and concomitantly his responsibility for it when he placed his resignation in the hands of the Company's president and it was accepted by him. ...

He earns income from the practice of that profession and from teaching. [3] At issue is the deductibility in computing the Appellant's income of expenses incurred in connection with two limited partnership units held by him, namely, one unit of Gerrard Associates Limited Partnership ("GA") and one unit of Collegeway Associates Limited Partnership ("CA"). [4] GA was formed in December 1986 with a view to acquiring a rental real estate project at 86 Gerrard Street East, Toronto, Ontario. ... He asserted that there exists no requirement that expenses incurred in connection with such adventures be deferred and added to the cost of the property which is the subject of the adventure. ...

Glengarry Bingo Association. [4] Both counsel have now acted on my invitation to make submissions in writing as to the impact of that decision on this case. [22] The Glengarry case raised the question whether a relationship of agency existed between Glengarry Bingo Association and the various charitable organizations which were members of it, in the context of an assessment for GST in connection with the furnishing by Glengarry to its members of the services of certain staff, and the provision to them of supplies, both for use in the operation of bingo events. ... Canada, [5] that the Court should take a common-sense approach to questions arising in connection with this legislation. ...

Pittman had had some trouble with Dean Muir in connection with the subject matter of item number 2. [14] As stated above, the issue is whether Dean Muir was an employee of the Appellant or an independent contractor. ... It had nothing to do with a business connection between Dean Muir and the Appellant's customers. ...

., 77 DTC 5198 at pp. 5200-5201: Finally, I should say on this point that the material submitted in support of this application does not, in my opinion, provide a reasonably arguable case for an exercise of judicial discretion increasing the fees for services of solicitors and counsel in connection with this appeal. ... All that has been established here is that the respondent incurred a very large solicitor and client bill in connection with the appeal, which would have been relevant if costs had been awarded on a solicitor and client basis but is not ordinarily relevant to the determination of costs on a party and party basis. ...

The Appellants' evidence, specifically the Appellant Krystyna Trela, was that she gave all her receipts and all the records that she had in connection with the business to an accountant by the name of Barbara at a firm by the name of Pagett's Accounting. ... It is for that reason only that the income statement had some relevance to her. [9]      There is no appeal before me in relation to the goods and services tax and the income statements, which were admitted into evidence as Exhibit A-2, have no relevance in connection with determining the accuracy or lack of it, of the net worth determinations of income of the two partners. ...

The hours do not seem unwarranted. [13]         Both Parties recognize the Rules leave me with discretion even in applying them in connection with substantial indemnity costs arising due to a settlement offer. ... While I did find, in the alternative, some elements of sham in connection with the Metropac loan, I did not accept the broad reach of sham argued for by the Respondent. ...

To this end, the City could grant subsidies to any person or organization involved in these activities to enable the City to meet the needs of its residents in accordance with the Charter of the Ville de Québec. [3] [20]         The Respondent submits that the two agreements entered into by the Appellant and the City of Québec established a direct connection between the subsidy and the University’s obligations to the City. [21]         In this regard, the Respondent submits that this supply is deemed to be a supply of real property under subsection 136(1) of the ETA. [22]         In the alternative, the respondent adds that, under Section 25 of Part VI of Schedule V of the ETA, if the Court were to conclude that the subsidy was granted for consideration, that supply was not exempt because it was primarily used in the course of the Appellant’s commercial activities. ... Qualification of the supply [66]         To qualify the supply, the Court must first look at the following definitions of subsection 123(1) of the ETA: commercial activity of a person means (a) a business carried on by the person (other than a business carried on without a reasonable expectation of profit by an individual, a personal trust or a partnership, all of the members of which are individuals), except to the extent to which the business involves the making of exempt supplies by the person, (b) an adventure or concern of the person in the nature of trade (other than an adventure or concern engaged in without a reasonable expectation of profit by an individual, a personal trust or a partnership, all of the members of which are individuals), except to the extent to which the adventure or concern involves the making of exempt supplies by the person, and (c) the making of a supply (other than an exempt supply) by the person of real property of the person, including anything done by the person in the course of or in connection with the making of the supply. […] exempt supply means a supply included in Schedule V. taxable supply means a supply that is made in the course of a commercial activity. [67]         In this case, we are dealing with a public sector body, as defined in subsection 123(1) of the ETA: public service body means a non­profit organization, a charity, a municipality, a school authority, a hospital authority, a public college or a university. public sector body means a government or a public service body. [68]         It is therefore necessary to refer to Part VI of Schedule V of the ETA and in particular to Sections 2 and 25 to determine which supplies are exempt with respect to public sector bodies. [69]         In addition, to qualify the supply, it is also necessary to look at the following definitions of subsection 123(1) of the ETA: personal property means property that is not real property. […] real property includes (a) in respect of property in the Province of Quebec, immovable property and every lease thereof, (b) in respect of property in any other place in Canada, messuages, lands and tenements of every nature and description and every estate or interest in real property, whether legal or equitable, and (c) a mobile home, a floating home and any leasehold or proprietary interest therein. [70]         Subsection 136(1) of the ETA defines the right to use real property as a supply of real property, and the same principle applies to the right to use tangible personal property: 136 (1) For the purposes of this Part, a supply, by way of lease, licence or similar arrangement, of the use or right to use real property or tangible personal property shall be deemed to be a supply of real property or tangible personal property, as the case may be. [71]         Section 2 of Part VI of Schedule V of the ETA provides that a supply made by a public institution of any personal property or a service is an exempt supply, notwithstanding the exceptions listed in this section. [72]         Thus, the issue is whether the University’s supply is a supply of personal property, services or real property. [73]         In this case, the agreements clearly refer to a right of access to PEPS facilities and real property. ...