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Instead, the Courts adopted an alternative test based upon the source of the taxpayer's profit. [95]          The Supreme Court of Canada, in Will-Kare Paving, supra, preferred the principles enunciated under the first line of authority (Crown Tire, supra), and concluded by stating:         For the taxation years in issue, approximately 75 per cent of the asphalt produced by the Will-Kare's plant was supplied in connection with Will-Kare's paving services. ... In the case at bar 100 per cent of the materials produced or purchased by the Appellant were supplied in connection with his taxidermy services. ... It said:         For the taxation years in issue, approximately 75 per cent of the asphalt produced by the Will-Kare's plant was supplied in connection with Will-Kare's paving services. ...

No other reasonable explanation or evidence in connection with the matter was proffered so I accept the explanation of the Appellant in this matter as credible. ... Frankly, short of evidence to the contrary being led by CRA, and in the absence of specific pleadings alleging the fact of illegality in connection with these transactions, the Appellant should not have to prove the source of funds on gifts given by third parties. ...   [94]          Even with respect to the Appellant’s mother-in-law’s gift of appliances discussed earlier, the auditor seemed anxious to find the Appellant’s connection to some illegal activities. ...

Krogel had been a manager at EBA and- in the spring of 1995- basically cloned the EBA system in Calgary using the new corporation which began doing business under the name of Innervision Crystal Connection (Innervision). ... Apart from his connection with EBA, Mazurat did not carry on any other business as a psychic, although he could have done so. ... Any advertisements placed by psychics in connection with that service were paid for by them but they still had to be approved by EBA to ensure they complied with CRTC regulations. ...

This afforded the Appellant the opportunity to purchase its gold at a substantial discount in relation to its market value. [9]              The Respondent observes that the gross margins earned by Diverse Equities, the Appellant, and the other intermediaries in the chain were unusually high, as demonstrated by the following table: Party Spot‑rate purchase Spot‑rate sale Margin Diverse Equities (purchaser and reseller) 93% 98.5%- 99.0% 5.5%- 6.0% Tricomcanada (Appellant) (purchaser and reseller) 90.5% 93.0% 2.5%- 4.75% [4] Tricom alleged suppliers (purchaser and reseller) n/a 90.5% Approximately 2.5% [5] Chèque Express (financial intermediary)     2.25% for cheque cashing services [10]         According to the Respondent, the aggregate gross profit margin of all of the participants in the chain was approximately equal to the unremitted GST and Quebec sales tax (“QST”), which was only partially refunded in connection with the transactions at issue in this appeal. ... Bijouterie Tiara filed for bankruptcy soon after it was assessed for GST and QST due in connection with its gold‑trading activities. [136]    I do not believe that Mr.  ... Al‑Romhein declared personal bankruptcy in July 2014, after he was reassessed for QST and GST owed by 9261 Quebec in connection with the transactions at issue in this matter and for income tax due in connection with funds that he allegedly appropriated from 9261 Quebec. ...

Question 2617 should be answered, but only to the extent that this question is aimed at having the Respondent divulge the relevant facts in connection with its reliance on paragraph 18(1)(b) and is not seeking evidence. 8. ... The Appellant has identified documents, asked why they have been included and the connection to the pleadings. ...

Does subsection 86(2) apply to deny the Appellant a full tax-free rollover in connection with the MDPC capital reorganization? ... [134]    The Respondent argued in the alternative that subparagraph 69(1)(b)(i) of the ITA applied in connection with the transfer of 85% of the common shares of MDPC equally to his wife and two daughters. ... She issued the reassessment incorrectly on the basis that subsection 86(2) applied so as to deny the Appellant a full tax-free rollover in connection with the capital reorganization of MDPC. ...

Court Reports [17]         In 2016, the Appraisers each produced a Court Report in connection with the current appeals pursuant to section 145 of the Tax Court Rules. ... Her original appraisal report was admitted in full and her expert report prepared in connection with the litigation was also allowed into evidence, notwithstanding the challenge raised by the Respondent’s counsel. ... For a witness proposed to be called as a litigation or independent expert for the purpose of litigation, the witness should be independent and impartial in respect to the litigation opinions that he or she formed in connection with a litigation that is either taking place, or is being contemplated. ...

The proper characterization of a commercial, contractual, business, work, or family relationship for purposes of the application of the federal Act will generally need to be determined in accordance with, or least after considering, the provincial law applicable to the relationship or transactions. [36] This limitation is compounded by the fact that Canada is a bijural common-law/civil law country and, in this case, the Appellant has some direct or indirect connections to the province of Quebec. [37] It is not clear that there is a federal meaning of the concept of debt, and neither of the parties asked the Court to adopt one. ... It follows that the availability of the manufacturing and processing incentives at issue must be restricted to property utilized in the supply of goods for sale and not extended to property primarily utilized in the supply of goods through contracts for work and materials. 30 It is perhaps true, as Will-Kare submitted and as noted in Halliburton, supra, at p. 5338, that the use of sale of goods law distinctions sometimes yields the anomalous result that the provision of services in connection with manufactured and processed goods will disqualify property that would, but for the services, qualify for the incentives. ... Principal/Principal Amount: [118] It appears from a review of the Act that, with limited exceptions, the words “principal amount” and “principal” are only ever used in connection with circumstances involving debts. [119] As mentioned above, paragraph 53(2)(c) and subsection 248(34) refer to the “principal amount” of “indebtedness”. ...

In connection with this, he went to Germany, probably in the fall of 1986 (the appellant himself does not recall exactly), to meet with the chief of the Association of Brew Masters in Berlin. ... I will simply quote here his remarks in connection to this: Again it was, it was the same sort of idea, we went just to get ideas, just to meet people for... about the business. ... In the appellant’s counsel written submissions it is stated that the one- day trip to Boston was in connection with a brewery convention. ...

It is a question which has been investigated very carefully in a number of different connections, and different matters of fact have been regarded in different cases as of importance and of weight The language used must be construed in reference to the particular facts of that case and the particular arguments which were being there put forward. ... He writes as follows at page 340 of his decision: In a case such as the present, the effect of the whole arrangement—and I must look at the whole arrangement—is that the trader receives a new capital asset, namely, the shares in the foreign company, in exchange for that which he previously had, namely, his connection or goodwill in the foreign country. ... Seidensticker without being constantly reminded of this close connection. ...