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Sexton J.A. did not deal with the elaborate operational infrastructure of Precision Gutters since that was considered to have been a separate business whose breadth and level of responsibility and financial connection with the end user was distinct from the business aspect of the installation process- in the narrow sense- as it applied to the installers ... Agreeing to work at $15 per hour in connection with any future contracts Marathon might obtain, does not seem to be consistent with what one would expect from an entrepreneur operating his own electrical contracting business ...

BELCOURT and RNB shall cooperate and work together in connection with any such negotiations and settlement, it being understood that any final decision with respect to payment of any such claim shall be made by RNB. 4.04 Any funds required in order to make the payments contemplated by this Article 4.00, and all costs, expenses and fees related thereto, shall be financed by RNB ("TAKE-OUT FINANCING") and, until such time as RNB is declared or otherwise becomes owner of the PROPERTY and sells forty-nine point nine percent (49.9%) of its interest in the PROPERTY to BELCOURT (as provided below), the aggregate of all such payments (as well as the advances described at Section 7.04 below) shall be added to and be deemed to form part of the RNB LOAN. [14] On February 4, 1991 (the agreement having been executed on February 1, 1991), title to the property was transferred from the debtor to the appellant (Exhibit A-7) by way of a voluntary dation en paiement pursuant to the Giving in Payment Clauses contained in the various Deeds of Loan between Yarkon and Yorkville (registered on October 31, 1986, June 8, 1988 and November 20, 1989), and in the Deed of Loan between the appellant and Yarkon registered on November 20, 1989, and pursuant to the 60-day notice registered on November 14, 1990. ... The price to be paid by MacLean in the event that he did exercise the option was the total of the balance of loans owing to Yarkon and the appellant under the different Deeds of Loan (notwithstanding the deemed payment under the voluntary cession) and the aggregate of the following amounts plus interest:- the amount paid by the appellant to Entreprise Federet Ltée ($945,0000);- all amounts paid by the appellant for privileges registered against the property;- all amounts expended by the appellant to maintain, improve and proceed with the construction or operation of the property;- all arrears of interest owed by the debtor to Yarkon and the appellant under the different Deeds of Loan;- all costs, expenses, disbursements and professional fees incurred by the appellant and Yarkon in connection with any of the foregoing payments in order to protect their rights in the property. [16] Mr. ...

Other issues in connection with the terms of the original Partnership Agreement arose too, and so the Agreement of Purchase and Sale had annexed to it an Amended and Restated Partnership Agreement to be executed by the original partners prior to closing. ... Wu, [17] Strayer J.A., in the context of subsection 15(1.1) of the Act, said: In this connection we refer to the decision of this Court in H.M. v. ...

The Courts reasoning is supported by Article 31 of the Vienna Convention On The Law of Treaties. 31(2) provides that for the purpose of the interpretation of a treaty, the context is comprised of the test, including its preamble and annexes, any agreement relating to the treaty which was made in connexion with the conclusion of the treaty, and any instrument which was made by one or more parties in connexion with the conclusion of the treaty. ...

The common law, however, has no such requirement: if there is preceding authority to act for the principal, the rules so far set out, other than those as to ratification, will apply despite the fact that the existence of the principal, or his connection with the transaction, is unknown to the third party. Where his existence or connection with the transaction is not known, the principal is referred to as undisclosed and the rules then applicable are referred to as the doctrine of the undisclosed principal, which can be regarded as a unique feature of common law. [74] The Civil Code also contemplates that the mandatary need not disclose the identity of his or her mandator but if the mandatary acts in his or her own name, the mandatary is liable to the third person. [24] [75] The two-cheque system was in effect in late 1988. ...

The respondent therefore requests that the appeals be dismissed (except, with respect to the 1993 taxation year, as regards an amount of $100 donated to another charity—having no connection with the instant case—which should have been considered in computing the credit for charitable donations allowed to the appellant for that year). ... The appeal from the assessment made for the 1993 taxation year is allowed and the assessment is referred back to the Minister of National Revenue for reconsideration and reassessment on the basis that the appellant is entitled to an amount of $100 donated to another charity (having no connection with the instant case) which should have been taken into account in computing the credit for charitable donations granted to the appellant for that year. ...

., (supra)... [52]         In a more recent decision dealing with third parties, GLP NT, supra, a motion was filed before this Court to compel the appellant’s nominee to answer questions about the relationships and connections amongst various corporate entities, which were all interacting together in one way or another. ... MacKay and the other directors took in connection with the purchase and sale of the property were steps calculated to give effect to the shareholders' instructions. ...

If this had not been the case, US and Foreign Investors in Blackstone Capital Partners would have incurred Canadian tax in connection with that sale. The Co-Investors have also incurred, undoubtedly, significant legal costs in connection with the establishment of the revised structure. [26]   Alta Canada carried out the development of its Working Interest in the Duvernay Formation in Northern Alberta (the Kaybob area of Alberta). ...

In this regard, consequential adjustments shall include the recognition of any capital gains or capital losses arising from the actual or deemed disposition of limited partnership units of AFS 7 … as described in paragraphs (e) and (f) above. [8] [Emphasis added.] [9]   Paragraphs (c) and (h) of section 5 (in the case of AFS 9) and paragraphs (c) and (h) of section 1 (in the case of AFS 11) of the Minutes contained similar provisions for 1998 and 1999. [10]   Section 8 of the Minutes provided that the Settlement was subject to the following conditions (which are paraphrased below): (a)   the Units owned by the Accepting Limited Partners were required to represent at least 75% of the total number of Units owned by the Qualifying Partners who were not deceased, bankrupt or non-residents of Canada; and (b)   each Accepting Limited Partner was required to provide to the CRA a waiver of the right to object or appeal under subsection 165(1.2) or 169(2.2) of the ITA, as the case may be, in respect of the adjustments contemplated by the Minutes. [9] [11]   Section 12 of the Minutes stated: For greater certainty and subject to any applicable limitation periods contained in the ITA, the terms of these Minutes of Settlement do not preclude the Minister of National Revenue from redetermining any expense or amount not expressly addressed by these Minutes in respect of Qualifying Partners, provided that such redetermination does not create a result that is inconsistent with the express terms of these Minutes. [10] [12]   On or about February 16, 2012, the Firm sent to the president of the General Partner of each of the Partnerships several memoranda, which were dated February 16, 2012 and which summarized the settlement offer (the “Settlement Offer”) that had been received from the CRA. [11] The Firm indicated that it was still working with the DoJ and the CRA “to fine tune some of the specific language of the Settlement Offer.” [12] The Firm also stated that similar offers were being provided by the CRA to the other Limited Partners who had been reassessed. [13]   The Firm’s memorandum of February 16, 2012 in respect of AFS 7 stated: Under the Settlement Offer, CRA will: (i)   allow slightly more than 78% of all operating expenses claimed by Alliance 6 in 1995 and 1996 which were allocated to the limited partners; [13] (ii)   allow 100% of all other expenses incurred by AFS 7 and Alliance 7 [sic] that were allocated to the limited partners; [14] and (iii)   allow 100% of all of the interest and financing charges incurred directly by the limited partners in connection with the investment in AFS 7. [15] The Firm’s memoranda of February 16, 2012 in respect AFS 9 and AFS 11 contained similar statements, except that the percentage stated in item (i) was 75.8% in the AFS 9 memorandum and 79% in the AFS 11 memorandum. [14]   On June 19, 2012, Mr.  ... In addition, subparagraphs 2(iii) to (v) of each Waiver stipulated that the CRA was to reassess him as follows: (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 an appeal or which is otherwise open for reassessment; (iv)   allows any consequential claims by me for the carryforward or carryback of any losses resulting from the reassessments as set forth above; and (v)   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. [17] [15]   While the Minutes and the Waivers specifically discussed the deductibility of the deductions claimed by Mr. ...

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. [53] [74]   This definition was applied to provide retroactive liability in the context of a section 160 assessment in Mario Côté Inc. v. ...