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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. ...

She also expended her own funds in connection with activities of the children carried out in Tumbler Ridge and attended events there even though the trip from Dawson Creek and back involved at least a three-hour drive under good road conditions. ...

However, the facts presented in those documents create a basis for inferences. [11] [21] The respondent’s written submissions argued that a sufficient year-end RRSP balance is a factor that the Minister considers in connection with applying s. 146.01(2)(d), according to administrative guidance. [12] That administrative guidance was from a conference roundtable in 2018. ...

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.     ...

    [116]      In a paper presented at the 1995 Canadian Tax Foundation Conference entitled “ New Rules, Old Chestnuts, and Emerging Jurisprudence: The Stop-Loss Rules ”, at p. 34:1, Edward Heakes described the policy underlying those rules in the Act as follows:   Tax legislators have long recognized that, in order to prevent undue erosion of the tax base, special rules are needed to deal with the recognition, denial, or deferral of losses for tax purposes that might otherwise be recognized on transfers of property between persons having a degree of connection or relationship with each other. ... An important variation, for the purposes of this case is in the degree of connection or relationship required between the transferor and transferee ...

Bowey, and with another accounting firm, with a view to obtaining tax advice in relation to the appellant’s business, not only in connection with the joint venture, but on a comprehensive basis. ... The human resource costs related to the expatriate connection and the technology cost related to the access that they had to technology. ...

Subsection 96(8) mandated the lower of cost or market in connection with a Canadian resident partner becoming a member of a foreign partnership. ...   [59]     I allow the appeal only in connection with the penalties imposed by CCRA, referring the matter back for reconsideration and reassessment on the basis that penalties are to be reduced to $100 each for 1992, 1993 and 1994. ...

Harvey has separately made a claim for an internet connection.   [52]         While I do not accept the figure put forward for home office use by Mr.  ... Harvey’s credibility, my specific view of his credibility in respect of the alleged 2003 trip to Victoria, the lack of any documentation supporting the 2003 and 2004 travel expenses, the lack of any documentary evidence of the existence of the conferences or seminars and the connection between the Toronto stopover and a family vacation, I am not prepared to allow Mr. ...