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In early December, she received the first daily reports prepared by employees in connection with the sale of alcoholic beverages over the course of approximately four weeks (Exhibit I‑9). ... Morand faced in connection with alcoholic beverage sales was different because, after making her second request to Michel Légaré, she finally obtained close to three months' worth of daily reports filled out by the employees, that is to say, the reports filled out from November 7, 1998, to January 31, 1999.  ... Richard in connection with the Appellant's sales. [138]    The Appellant's expert Marc Bélanger admitted that, apart from the unreported and unremitted GST, the Appellant owed an additional $14,542 in GST on unreported sales that he estimated at $389,473 (Exhibit A‑28, at pages 6 and 7). ...

He described this as a “contingency plan” in case he had to repay the loans incurred in connection with the Program. ... His spouse received similar invoices in connection with her loans. Prior to paying those amounts, he called Mr. ... In any event, he repeated the process and donated $150,000 in 2003 but reduced the donation to $30,000 for 2004 and 2005. [87] In connection with the various loans, he understood that he was responsible for the shortfall. ...

  [8]               The fourth ruling I wish to mention is in connection with a line of questioning Appellant’s counsel wished to ask Mr. ... I conclude, particularly in connection with Ms. Henderson’s report, which I shall discuss in more detail later, that the experts present more as judges of horses’ qualities for the purposes of competition, rather than valuators for the purpose of commercial investment ... This would result in $7,600 being a taxable withdrawal in connection with the R Corporation. ...

Most of the swaps were part of GWL’s planning for the Bestfoods acquisition and were implemented in connection with, and as a result of, that important acquisition. ... Under this test, the appellant argued, the same conclusion as above is reached; the swap proceeds were received in connection with GWL’s capital structure and were therefore on capital account. ... Work expended on or in connection with the property realized. If effort is put into bringing the property into a more marketable condition during the ownership of the taxpayer or if special efforts are made to find or attract purchasers (such as the opening of an office or advertising) there is some evidence of dealing in the property. 5.   ...

In this connection he mentioned in particular the Métro name, the prestige connected with this banner and the advertising done by Métro. ... Brunetta noted that Métro secured two important benefits: a long-term connection with a food merchant and a better concentration of purchasing of its products. ... That penalty and the ratios required however have no connection with the volume discount or other discounts currently in use. — Right of first refusal over the sale of the business or shares of the company, right to a possible lease of the premises of the food market. ...

However, it is our opinion that Mersey Seafoods Limited has no manufacturing or processing profits, in connection with the “Mersey Viking” since the activities started out aboard the vessel were not performed by employees of the company but rather by self-employed individuals. ... If the activity did not occur in Canada it is not a “qualified activity”, which is defined in regulation 5202 as one “... performed in Canada in connection with manufacturing or processing...”. ... For the purposes of this Act, “Canada” is hereby declared to include and to have always included (a) the sea bed and subsoil of the submarine areas adjacent to the coasts of Canada in respect of which the Government of Canada or of a province grants a right, licence or privilege to explore for, drill for or take any minerals, petroleum, natural gas or any related hydrocarbons; and (b) the seas and airspace above the submarine areas referred to in paragraph (a) in respect of any activities carried on in connection with the exploration for or exploitation of the minerals, petroleum, natural gas or hydrocarbons referred to in that paragraph. ...

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. [9]              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. [10]         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: [91]         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. [92]         As mentioned above, paragraph 53(2)(c) and subsection 248(34) refer to the “principal amount” of “indebtedness”. ...

In the interim, Motiuk stated she received requests for information and applications for social insurance numbers or UI benefits which, although some of them might have been farm labourers, had no connection to her regular duties or to the function of the AES office. ... The necessary computer program was operated by the Regional Informatics Branch- a creation of the federal government- and AES staff received training on that system in Edmonton and all expenses in connection with attendance for that purpose were paid, even if a local operating budget had to be amended and more money supplied by HRDC in a forthcoming monthly cheque to cover those costs. ... This is particularly true when the person has no prior employment connection with the party who benefits from his services. ...

The matter of ties within the jurisdiction asserting residence and elsewhere runs the gamut of an individual's connections and commitments: property and investment, employment, family, business, cultural and social are examples, again not purporting to be exhaustive. ... There the             question is whether that person has become "ordinarily resident" in Canada; (c) cases where a Canadian resident leaves Canada and severs his           or her connection with this country so that he or she is not a     Canadian resident, and then reacquires ties here. ... This is shown by the various factors, which have already been related which indicated that he still had substantial connections to Canada. [115]        In essence counsel argued that on the totality of evidence, the Appellant's presence in the U.S. in the years in question was temporary and his ties to Canada, albeit not as deep-rooted as one would expect if somebody resided in Canada for 15 or 20 years, since he was a recent immigrant from Nigeria to Canada, indicate that his intention was to come back to Canada. [116]        There are a number of references in the evidence to correspondence between the Appellant and the C.C.R.A., where he expressly stated that he would be returning to Canada upon the conclusion of his program and at the end of the day he did return to Canada. ...

In connection with the matters described in subparagraphs (a) through (i), the Association has paid or incurred legal fees of approximately $1,500,000. 39. ... The cost of the annual education seminars is covered by a grant received from the Alberta Government. [4]           Neither party called any witnesses nor produced any further documents in evidence. [5]           Counsel for the appellants submitted the issue to be decided is as follows: Whether the amounts paid by the appellants to the Alberta Provincial Judges' Association are membership dues in an association of public servants the primary purpose of which is to promote the improvement of its members' conditions of employment or work pursuant to subparagraph 8(1)(i))iv) of the Act. [6]           Although pleaded- in the alternative- in each Notice of Appeal filed on behalf of each appellant, submission on the issue of deductibility of membership dues pursuant to paragraph 8(1)(b) of the Act- on the basis there was a connection between payment of Association dues and the establishment of a right to salary or wages owed to each appellant- and to all other judges of the Provincial Court of Alberta- was abandoned by counsel for the appellants. [7]      The relevant portions of subparagraph 8(1)(i)(iv) of the Act read as follows: 8. (1) In computing a taxpayer's income for a taxation year from an office or employment, there may be deducted such of the following amounts as are wholly applicable to that source or such part of the following amounts as may reasonably be regarded as applicable thereto:...    ... It would have been extremely difficult to consider the total amount of the membership fee and to somehow attribute an appropriate portion thereof directly to each member's pro rata cost of the global litigation which, inter alia, produced the salary reimbursement as opposed to allocations in respect of other Association activities, such as costs incurred in connection with conferences and meetings having other purposes. [40]     The assessment(s) of the Minister- as they apply to each appellant- are valid. ...