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The Concord Parties, with KPMG Accounting and Farris Vaughan Wills & Murphy (Farris Law) acting on their behalf, engaged Moskowitz Law to provide legal advice. [67] Moskowitz Law’s role was to provide legal advice to the Concord Parties in connection with certain tax matters, based on facts provided by the Concord Parties, Farris Law, and KPMG Accounting. [68] KPMG Accounting’s role was to act as agent on behalf of the Concord Parties to retain Moskowitz Law and to provide Moskowitz Law with factual and other information. [69] The particular role of Farris Law is less clear because the Appellant has not provided affidavit evidence in this regard. [70] Although Farris Law is described as an agent for the Concord Parties, the Engagement Letter indicates that Farris Law also would be providing legal advice to the Concord Parties. ... First, in some instances the document on its face contains insufficient information, because neither the author nor the recipient is listed and there is no clear connection to the provision of legal advice. [47] [75] Second, in other instances KPMG Accounting provided independent legal advice beyond the scope of its role as agent under the Engagement Letter. ...

The appellants in that case claimed that they believed they had resigned, but the Federal Court of Appeal stated the following: [19] A director’s belief that they have resigned has no correspondence or connection to the underlying purposes of subsection 121(2) of the OBCA and its emphasis on an objectively verifiable communication of a resignation to the corporation. ... In the end, even if this Court accepts that the original letter of resignation was given to Leventis, he was a third person who had no legal connection to the corporation. ...

Paragraph (c) of the definition states that a commercial activity means “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”. [17] The Appellant’s sale of the Condominium was a supply of real property of the Appellant. ... Paragraph 141.1(3)(a) provides that to the extent that a person does anything (other than make a supply) in connection with the establishment of a commercial activity of the person, the person is deemed to have done that thing in the course of commercial activities of the person. [46] It appears from the ASF that the first step that the Appellant took to establish the commercial activity of leasing the Condominium on short-term leases was the listing of the Condominium on the Airbnb website on February 25, 2017. ...

Only modification is relevant in this appeal. [46] The AR EPA is an agreement to make a taxable supply: the supply of electricity. [47] The expression “as a consequence of” requires some causal connection or link. This causal connection to the modification of the original term of the Bone Creek EPA is set out in section 2.2(d) of the AR EPA, which provides that the Payment is “in consideration of the opportunity provided to the Buyer to extend the Term pursuant to section 2.2(a)”. [48] BC Hydro asserts the Payment was made as a consequence of the modification to the Bone Creek EPA to add the Optional Term Extension to the AR EPA. [49] BC Hydro’s internal documents confirm that the Payment was made for the modification or amendment of the Bone Creek EPA. [9] Disputed Condition 2: the consideration is not consideration for “the” supply [50] Subsection 182(1) of the ETA requires that the payment be made as a consequence of the breach, modification or termination of an agreement for making “a taxable supply”, it must not be consideration “for the supply”. [51] Both the original Bone Creek EPA and the AR EPA are agreements for making the taxable supply of electricity. [52] This means the Payment cannot have been for the supply of electricity under the AR EPA; or in other words, it must have been for something other than the supply of electricity. [53] The Payment was to compensate Valisa for agreeing to modify the Bone Creek EPA to add the Optional Term Extension. ...

However, the Courts, in considering this phrase, have given wide latitude to those words emphasizing “…that only the smallest connection to employment is required to trigger the operation of the section” (The Queen v. ... Yonge-Eglington Building Ltd., 74 DTC 6180, at page 6184 observed that:   … the words … are used in the sense of 'in connection with' or 'incidental to' or 'arising from' and refer to the process of carrying out the borrowing for or in connection with which the expenses are incurred ...   [66]     Pursuant to the OPBA, GMCL, the employer acting as a plan administrator of pension assets, assumes various fiduciary responsibilities in connection with the Plan’s administration and management. ...

Staltari was conducting a business and that the Land was acquired, owned and disposed of in connection with that business, there would need to be evidence tying Mr. ... Staltari personally conducted a business in 2000 and that he acquired the Land in connection with that business. ... In fact, the donation was made for personal reasons — to save personal income tax – and not in connection with a business conducted by Mr. ...

The Queen. [11] The Appellant asserts that the causal connection between the debt reduction and the Payment is not strong enough to meet the requirement imposed by subsection 182(1).   ...   [90]    The Respondent agrees that the words “as a consequence of” require a causal connection. However, the Respondent argues that a sufficient causal connection exists here as the Payment inevitably had to benefit to Mall Co as reflected in the chain of book entries identified and acknowledged at the hearing. ...

In connection with those matters and as further exploration and development work is carried out on those properties they will use their best efforts to reach definitive agreements.  ... The Quarter Claim Agreement states that the royalty will be payable to Teck/Corona after Norex has recouped its capital outlays in connection with the mining of the ore, but not including capital costs relating to the shaft. ... The royalty will be payable to T/C after Norex has recouped its capital outlays in connection with the mining of that ore, but not including Shaft costs all as more fully described in Schedule D hereto ...

In this connection I refer to the following cases.   35  Firstly, in Gestion B. ... Expenditures for seismic data pertaining to the appellant’s connection with the Sierra Joint Venture were essentially the matter specified in the waiver. ... Dunbar’s letter of April 4, 1996,  to notify the CRA that he had no connection with any seismic data purchases. ...

RECL was not obliged to receive any LNG pursuant to this agreement unless it met standards set out in the agreement in connection with heating value, WOBBE number (I gather an index indicating flammability), hydrogen sulphide content, sulphur content, non-hydrocarbon gas content, carbon dioxide content, nitrogen content, oxygen content, no water or mercury, no active bacteria and no toxic substances.              5.       ... Ribbeck’s assessment of risk was proven to be prophetic as, due to changes in the LNG market and given guaranteed commitments Repsol had made to Irving, by 2013, Repsol wrote down the value of the assets in connection with the Terminal by $1.2 billion. [38]         In computing the income of the Canaport Partnership with respect to its 2007 and 2008 fiscal periods, Repsol classified the cost of acquisition of the Terminal and the Jetty as properties falling in Class 43 of the Income Tax Regulations (the “ Regulations ”) and, consequently, claimed ITCs pursuant to subsection 127(5) of the Act with respect to those assets. [39]         The Minister ultimately reassessed the Appellants for the 2007 and 2008 taxation years in June 2010 by determining that the Terminal was a plant and property that fell in Class 1(n) of the Regulations, which does not attract ITCs pursuant to subsection 127(5) of the Act. ... The foundation was part of the processing. [88]         Applying these principles to the connection between the Jetty and Terminal, can the Jetty be considered ancillary and necessary, and part of the integral totality of the operation occurring at the Terminal? ...