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Personal relations and attitudes toward each other are often as important in this connection as the place of physical residence. ...

The Agency Agreement also contains a disposition releasing the Foundation from any liability and expenses in connection with personal injury arising from his work. [33] However, the Agency Agreement also contains various provisions, which show that the Foundation controls various aspects of the activities undertaken by Mr. ...

I take the fact that his sister would cook for him as an indicator of his connection with family near the Property rather than as an indication that the Property was not a place of residence. [26] When he moved into the Property, Mr. ...

Kirzner’s information collection process in connection with his retainer; (ii) Mr. ...

Back then, the appellant filed notices of objection with respect to 1995, 1996, 1997, and 1998 within time. [5] There were also apparently outstanding related objections for 1992, 1993, and 1994. [6] [8] Approximately 1,200 taxpayers (including the appellant) were similarly reassessed by the Minister with respect to limited-partnership holdings in AFS and several other similar limited partnerships. [7] The parties reached a group settlement and minutes of settlement were executed in February 2012. [8] During the present hearing, counsel for the appellant invited the Court to review the details of the settlement as set out in Savics at the Tax Court level. [9] [9] For the purposes of this appeal, the relevant aspects of the settlement were that: (a) a portion of the previously disallowed non-capital (partnership) loss from 1995 would be allowed, and (b) if the appellant wished to avail himself of the settlement, he was required to sign a waiver of the right to object or appeal. [10] The Minister was also permitted to make adjustments not expressly addressed in the minutes, as long as they were not inconsistent with the express terms of the minutes. [11] [10] The relevant terms of the settlement are set out in the document entitled “Waiver of Right of Objection or Appeal” which the appellant executed on November 28, 2013. [12] The waiver provided (among other things) that he agreed to waive any right of objection or appeal to his 1995 and following taxation years with respect to AFS on condition that the Minister reassess him as follows: (i) allows me to claim as a deduction in my taxation year that includes December 31, 1995, the full amount of all deductions claimed by me in respect of the Partnership (including all interest, carrying charges and partnership losses) for such year less an amount equal to $355.23 per limited partnership unit of the Partnership held by me at the end of 1995; (ii) allows me to claim as a deduction in my taxation year that includes December 31, 1996, the full amount of all deductions claimed by me in respect of the Partnership (including all interest, carrying charges and partnership losses) for such year less an amount equal to $16.20 per limited partnership unit of the Partnership held by me at the end of 1996; (iii) allows all interest expense and carrying charges previously claimed by me in respect of the Partnership in any taxation year in which I have filed an objection or appeal or which is otherwise open for reassessment; (iv) allows me to claim interest expense in respect of my taxation year which includes the period from January 1, 2011 to January 17, 2011 in the amount of $3.07 per limited partnership unit of the Partnership held by me during that period; (v) allows any consequential claims by me for the carryforward or carryback of any losses resulting from the reassessments set forth above; and (vi) unless otherwise agreed to by me, does not make any other adjustment to my tax liability in connection with my investment in, or ownership of, limited partnership units of the Partnership other than consequential adjustments or other adjustments that are not expressly addressed by, and do not create a result that is inconsistent with, any of the preceding terms of the Waiver[sic]. [11] On June 30, 2014, the Canada Revenue Agency’s Appeals Division sent a letter to the appellant setting out the adjustments which would be made pursuant to the settlement. [13] The letter attached a settlement worksheet, copies of T7W-C forms explaining the changes with respect to 1995, 1996, and 1998, plus stated (among other things) that: a. additional non-capital losses of $304,374 would be allowed with respect to 1995; b. of the $304,374 loss, $260,312 would be carried back to 1992 and $44,062 would be carried back to 1993, thus using up the loss amount; and with respect to the years under appeal (1997 and 1998), no adjustments would be made to 1997 because net adjustments would result in an upward assessment while a carrying charge would be allowed for 1998. [12] Notices of reassessment were also issued on June 30, 2014 for the 1992, 1993, and 1998 taxation years, effecting the changes described in the letter. [14] The parties’ positions [13] The appellant says that the Minister improperly carried the $304,374 non-capital loss back to 1992 and 1993, because she did so without giving him a choice as to the application of the loss. ...

More specifically, the respondent's questions have to do with the nature of and reason for certain money transfers sent to certain individuals, their role in the business, payments made by cheque to certain businesses, their connection with the business, and certain automatic transfers or withdrawals. [20] According to the appellants, the questions for corporation 9291 concerning its expenses are not relevant because the reassessments are based on an electronic comparison of sales according to the bank account and sales according to the SRM (or sales recording module). ...

Azmayesh-Fard for the 1998 to 2015 taxation years to include in his income amounts in connection with the Swiss Bank Account and to make some other, smaller adjustments. ...

(My emphasis.) [74] While recognizing that the liability of directors is not absolute, the test raises the bar and imposes a higher standard of care where the directors are aware that the corporation is facing financial difficulties. [75] In this instance, there is little doubt that the Appellant was acutely aware of the corporation’s financial difficulties by the end of June 30, 2014. [76] During that reporting period, the corporation reported sales of $2,000,000 but was unable to remit net tax of $243,000 by the due date. [77] From this point in time, it can be said that the bulk of the Appellant’s efforts in connection with the GST was to make advances to the corporation to ensure payment of net tax owed for that reporting period. ...

Bowman played an important role in connection with the 1998 reorganization. ... Michael informed of anything in connection with these transactions except when it was necessary for agreements to be signed ... It does not matter that the Trusts have few connections with Barbados. ...

Bare Trust Agreement.-             Exhibit A-1, Table 6: “ the guidelines setting out the rules applicable to members in connection with the Intrawest program. ” (the Membership Guidelines)-             Exhibit A-1, Table 8: The document entitled Purchase and Membership Agreement which agreement was entered into by the Canadian Developer and a Canadian Resort Point Purchaser (the Canadian Purchase and Membership Agreement)-             Exhibit A-3: A document entitled Membership Certificate [18]         As noted in paragraph 13 of the PASF, the parties are satisfied that the documents at Exhibits A-1 and A-2 are materially representative of these documents for the period between 2002 and 2007. ... As noted in paragraph 21(a) of the PASF, the principal rights that a Member of the Appellant has in connection with the Intrawest Program are the following: (a)   the right to use resort points held by the member to reserve the use of the vacation homes in accordance with the Guidelines [the Membership Guidelines] as established by the developer [the Canadian Developer]. [116]    This is a contractual right. ... Section 10.3 of the master declaration states that Membership Costs “shall include but not be limited to:” (a)   The maintenance, repair, modification, alteration, redecoration, or replacement of any Resort Accommodation; (b)   The maintenance, repair, modification, alteration, redecoration, replacement, and rental of the Equipment; (c)    Insurance coverage; (d)   A capital contribution for reserves; (e)    Domestic services, including cleaning and maid service, the frequency which shall be determined from time to time by the Board, furnished to or on behalf of Members; (f)    Assessment levied against Resort Accommodations by a Project or association for a Project; and (g)   Any other costs incurred by the Club in connection with the maintenance, repair, replacement, restoration, redecoration, improvement, operation, and administration of the Resort Accommodations, or in connection with the operation or administration of the Club, which are directly attributable to the commitment of one (1) or more Resort Accommodations in accordance with the provisions [of the Master Declaration]. 29.     ...