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Dow indemnified Sun Life against any damage, liability and expenses which resulted from claims or lawsuits brought against Sun Life in connection with the Plan or the ASO Contract; c)      Clause 10: Sun Life opened a bank account in its name which was used solely in connection with the Plan and the ASO Contract. ...

There are potentially a number of factual elements – the purpose of the payments, the business carried on by CIBC, the factual connection or absence of a factual connection between the two – that might have been the subject of factual assumptions made by the Minister in reaching the conclusion that the income earning purpose in paragraph 18(1)(a) was not met. ...

Sandberg had the connections and skills necessary to conduct this work, especially in convincing the band leadership to cooperate ... However, he backtracked from this when he was shown a statement that he signed in connection with bankruptcy proceedings in September 2005 which did not list any income from Frontier ...

Dussault, J.T.C.C. [1] The respondent has brought in connection with the appeal by each of the appellants a motion the main purpose of which is to obtain an order granting leave to withdraw admissions that her representative made in an examination for discovery held on March 27, 1998. [2] In 1991 and 1992, the appellants signed contracts with some Quebec universities. ... The second matter is one of the points in issue in ultimately determining whether the appellants are entitled to the input tax credits claimed in connection with these contracts. [3] On March 27, 1998, Guy Du Pont, one of the appellants’ counsel, conducted an examination for discovery of Luc Guénette, an auditor with the Direction générale de la vérification et des enquêtes (audit and investigation branch) of the Quebec Department of Revenue. ...

The evidence is straightforward and un-equivocating on this point. [25]          On this basis I find that the Minister was correct in denying the Applicant’s application, received March 28, 2013, for the NHR. [26]          In connection at least with the NHR, the Respondent presented at the hearing a further argument that there was no amending agreement to move the brothers’ father off the purchase and sale agreement and the two brothers on. ... The same is true of this Court, and is fundamental to this Court’s responsibility to interpret and apply the law, whether on an appeal that leads to this Court agreeing with or over-ruling the Minister’s decision-making on the point(s) appealed. [31]          Also, the Appellant as noted above seemingly has pleaded that alternatively he is appealing:... from the suspension, pursuant to subsection 188.2(2) of the Income Tax Act, of its authority to issue an official receipt referred to in Part XXXV of the Income Tax Regulations. [32]          With respect, this provision addresses charitable gift receipts, and thus has no connection or relevance to the case at bar. [33]          I turn now to subsection 296(2.1) of the Act, pleaded by the Appellant. ...

Excluded are security deposits and damage and loss reimbursement payments. [4]   Sections 4 and 5 under the heading “Owner’s Joint Venture Contributions” provide that the Owner agrees to make each Property available for leasing and use for benefit of each JV and to pay for its expenses in connection with each JV per terms of the JVA. ... Section 16, re “GST”, provides that each of Owner and MC is responsible for remitting GST per the Act collected in respect of commercial rents according to their proportionate interests in the GROI and shall be entitled to own ITCs in respect of property and services consumed, used or supplied in connection therewith. ...

(g) precisely 12 minutes before the close of business on the deadline set by this Court, the Respondent advised the Appellants that: (i)   She considered that the Appellants’ request was “not mandatory” under the Rules: (ii)   She would be willing to provide only a small portion of the documents requested; (iii)   before She did so, the Appellants must give undertakings not mandated by the Rules of this Court that would effectively prevent the Appellants from making any effective use of the documents in the prosecution of these appeals: and (iv)   the Respondent had redacted or excluded documents containing taxpayer information within the meaning of section 241 of the Income Tax Act. [14]   To be fair to the Respondent, its’ letter of September 28, 2018 offered to provide the Appellants with over 16,000 documents and contained conditions that the Appellants sign an acknowledgment that these documents are to be used only in connection with these matters in accordance with the implied undertaking rule and that they would respect the confidentiality requirements of section 241 and thus not disclose that personal information set out in that section. ... The Order was clearly intended to move the matter along so that, absent agreement, the Appellants could bring a motion for document disclosure beyond the Rule 81 list of documents that had already been exchanged over a year earlier, if they chose to and do so knowing what, if any, matters would be in dispute in connection therewith. [25]   The fact the Appellants were not satisfied with the Respondent’s reply does not mean the Respondent did not comply with my Order, nor does it matter that the Respondent replied on the last day as same was still within the time given under the Order in question. ...

The appellants also submit that, since all the documents and information related to the underlying reassessments were, and are, in the possession of the Canada Revenue Agency (the “CRA”), the onus is on the respondent to prove the correctness of the underlying reassessments. [5]   With respect to Newgate’s underlying reassessments for the 2005 and 2006 taxation years, the respondent argues that because of the appellants’ connection with Newgate, the burden of proof should not be reversed and the appellants bear the burden of proving that the underlying reassessments are incorrect. ... There was therefore a sufficient connection with Newgate to justify not reversing the onus with respect to those taxation years. ...

There was no evidence to suggest that he had purchased properties other than 310 Cranston Park and the Property. [41]   Before he secured stable employment with the TTC, the Appellant did an eclectic series of jobs, none of which had a close connection to real estate transactions. ... Their father’s occupation as a cabinet maker is related to residential and/or commercial interiors, but the connection to real estate transactions is remote. [43]   Therefore, this factor favors a finding on account of capital. (3) The nature of the property and the use made of it by the taxpayer [44]   The Property is a residential apartment-style condominium which sold relatively quickly after it was listed. ...

He did not establish any connection between the total amount of the alleged gifts and the total amount of deposits to his personal bank accounts in 2013 and 2014. d)   Mr. ... Conclusion [30]   It is unlikely that a taxpayer who was in a position to make an equalization payment of $425,000 between 2012 and 2014 would have earned less than $11,000 in 2013 and less than $25,000 in 2014. [31]   In this connection, it is worth recalling why Mr. ...