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Consequently, the due date for the Application in connection with the Property is the date that is two years after the Substantial Completion Date for the Property. ... Morgan’s dealings with the CRA in connection with the Application, neither Mr. ...

The appellants’ assertion that the Services were a fulfillment of their contractual obligations to their employees and provision of such benefits improves employee recruitment, retention, and morale are very likely accurate; however, it not a sufficient nexus or connection between the Services and the employer’s activities to displace the highly personal nature of these supplies. [21] Therefore, I am of the view that the appellants intended for the Services to be for the exclusive personal use of their employees. [22] [31] Approaching the question from the perspective of the second prong of the ExxonMobil test, it is difficult to reasonably conclude that the Services were used by the appellants’ employees in the course of their employment activities, as I would expect them to access these types of services on their personal time. As noted by this Court in Westcoast Energy, the connection between the use of the Services and the employee’s employment activities is even more tenuous when the employee’s family member receives the supply. [23] In these circumstances, it cannot be concluded that the Services are for consumption or use in relation to the appellants’ activities. [32] Evidence of Parliamentary intent should be clear. ...

Other concerns were addressed but no mention was made of the Appellant as an occupant. [19] Turning to the documents produced at the hearing, the Appellant testified that she arranged for an internet connection at the Rebate Property but was unable to produce a receipt. [20] She produced invoices for construction materials to be delivered to the Rebate Property as well as confirmation of property insurance and electricity bills, all showing the address of the Rebate Property. [21] A washer and dryer were delivered in mid-November 2019. [22] She also produced a screen shot of a bank account with CIBC showing the address of the Rebate Property. ... No explanation was provided for their absence or failure to testify. [37] The Court was not provided with the name of the contractor or his connection with the Appellant. ...

Carl terminated Bird's services and assumed the duties formerly carried out by him for the benefit of Synertech in connection with a project for the Ministry of Health (Ministry), the end user. ... Instead, it is a contract between VML and Cardinal wherein VML agrees to provide its services at a certain hourly rate to perform tasks in connection with the services Cardinal had contracted to provide to the Ministry of Health. ... There was no evidence adduced that any employee or official of the provincial government had any contact whatsoever with Haas in connection with the provision of his services. ...

ERCB's letter in this connections is attached as Exhibit 29. 27. ... Attached as Exhibit 31 is a November 15, 1995 note from the NEB to Rainbow attaching two NEB Press Releases in connection with the proposed SCC inquiry. ... He then proceeds to state: In connection with the preparation of this opinion, I spoke with either a representative of the above three reporting issuers or their auditors. ...

Pursuant to paragraph 4(a) of the ASO Contract, Westcoast retained all final authority and responsibility for each plan and its operation, and Manulife was empowered to act on behalf of Westcoast in connection with each plan to the extent contemplated by the ASO Contract. ... They import such meanings as “ in relation to ”, “with reference to” or “in connection with”. The phrase “in respect of” is probably the widest of any expression intended to convey some connection between two related subject matters. [21] [Emphasis added.] ...

Rather, the Appellant filed its tax returns as a non-resident and the Minister accepted them as filed.” [47] [61] The Court agrees with the Respondent that this argument must be rejected and relies on the analysis set out above in connection with the issue of estoppel. ... It follows that the Minister was entitled to issue the reassessment in connection with the subject capital gain. ... Conclusion [110] For all the foregoing reasons, the appeal is again dismissed with costs to the Respondent in connection with this redetermination only. ...

[Emphasis added.] [30] Courts have found that there must be a “sufficient nexus or connection” between the input and the commercial activity. ... Yonge Eglington Building Ltd., 74 D.T.C. 6180, at page 6184, where the words “in connection with”, or “incidental to”, or “arising from” were suggested. ... The fees were paid in connection with group health benefits offered by Great‑West to employers. ...

Accordingly, a deduction cannot be so far removed from its corresponding income stream as to render its connection to the anticipated income tenuous at best. ... Where a loan is made for the purpose of earning income through the payment of dividends, this connection is sufficient to satisfy the purpose requirement of subparagraph 40(2)(g)(ii) ... The determination of whether there is sufficient connection between the taxpayer and the income earning potential of the debtor will be decided on a case by case basis depending on the particular circumstances involved. ...

But the fact that the BC Government may have a broader purpose does not eradicate the fact that there remained an immediate purpose to assist BC Transit with its only activity of making a taxable supply, which falls squarely within subsection 141.01(1.2). [62]     As subsection 141.01(1.2) applies, and the Grants are considered consideration, BC Transit, by the application of subsection 141.01(2) is entitled to ITCs in connection with the Vehicle appeal. ... I vary the reassessment in connection with the Real Property appeal by allowing BC Transit ITCs of $3,420,897.90, and I vary the reassessment in connection with the Vehicle appeal by allowing BC Transit ITCs of $335,862.42. ...