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The only reimbursement by CKUA for expenses incurred by Burton or other account executives was in connection with travel outside their designated sales territory or in the instance where Burton was reimbursed the cost of a civic luncheon because the General Manager (GM) of CKUA was unavailable and had requested her to attend on his behalf and represent CKUA. ... Burton used the computer at the CKUA office in connection with making her sales but that was never a requirement of her contract. ... Her expenses in connection with attending a luncheon- at which she substituted for the GM of CKUA- were paid by the appellant. ...

The distinction was pointed out by Davies J in connection with similar words used in s.26AAA(4) of the Act in Barnsdall v. ... The Commissioner is required to be satisfied not merely of a connection between a taxpayer and the person to whom the taxpayer transferred, but also of the fact that they were not dealing with each other at arm's length. A finding as to a connection between the parties is simply a step in the course of reasoning and will not be determinative unless it leads to the ultimate conclusion. ...

A number of cases were cited in connection with the arm's length issue, including Peter Cundill & Associates Limited v. ... Moreover, the lengthy reasons of the Judge below fail to disclose any misconduct anterior to the litigation that could be imputed to the Commission and be considered as sufficiently serious and as having a close enough connection with the litigation to warrant such an award. ... (c) a payment of a dividend contrary to section 42,... are jointly and severally liable to restore to the corporation any amounts so distributed or paid and not otherwise recovered by the corporation.... 118(4) Recovery A director liable under subsection (2) is entitled to apply to a court for an order compelling a shareholder or other recipient to pay or deliver to the director any money or property that was paid or distributed to the shareholder or other recipient contrary to section 34, 35, 36, 41, 42, 44, 124, 190 or 241. 118(5) Order of court In connection with an application under subsection (4) a court may, if it is satisfied that it is equitable to do so, (a) order a shareholder or other recipient to pay or deliver to a director any money or property that was paid or distributed to the shareholder or other recipient contrary to section 34, 35, 36, 41, 42, 44, 124, 190 or 241;... ...

There was a large amount of contradictory evidence in connection with these matters heard in this appeal and the credibility of many of the witnesses are in issue, although it is safe to say that many of the witnesses had credibility problems on at least some of the issues but not all. ... She testified she used this account to make down payments on her Collingwood condominium, live on after she left 145, deposit rent cheques from 145 in connection with her ownership of 89 Shorncliffe and deposit the proceeds of her house sale into as well as draw the funds to pay off her mortgage on the Collingwood condo. ... A tremendous amount of evidence was heard in connection with these other assumptions dealing with the underlying basis for the reassessment against the Appellant and although it is not necessary for me to explore them further in order to arrive at the conclusion I have arrived at, I do believe addressing some of these issues will further support my conclusion as well as highlight the issues of credibility that were raised in this matter.   ...

On the other hand, however, “the courts have been disinclined to restrict the right to contract, particularly when that right has been exercised by knowledgeable persons of equal bargaining power”. 35 While an overly broad restraint on an individual's freedom to compete will generally be unenforceable, the courts must recognize and afford “reasonable protection to trade secrets, confidential information, and trade connections of the employer.”… 36 … But how is a court to determine whether any given restrictive covenant is “reasonable”? ... There are potentially a number of factual elements – the purpose of the payments, the business carried on by CIBC, the factual connection or absence of a factual connection between the two – that might have been the subject of factual assumptions made by the Minister in reaching the conclusion that the income earning purpose in paragraph 18(1)(a) was not met. ...

Elavon will provide MSP with access to the approved form of merchant application and copies of the Merchant Agreements (currently comprised of “Terms of Service” and “Merchant Operating Guide”) that must be provided to all merchants in connection with the services offered.   2.5   Ownership of Referred Merchants. ... “Program Standards” means the credit criteria, standards and policies and procedures established by First Data, to be used by ISO in connection with the solicitation of prospective Merchants and other policies, procedures, fines and penalties established by First Data, that are designed to promote Merchant satisfaction, to preserve relationships with existing Merchants, to facilitate the growth of the Program, and to ensure the financial safety or soundness of First Data and its Program. ... (c) ISO shall obtain such information and take such action as First Data may from time to time reasonably require in connection with their processing of prospective Merchants, including:   (i) Fully complete and submit, to First Data, a Merchant Application for each Merchant;   (ii) Implement and document procedures to verify that each Merchant conducts or intends to conduct a bona fide business operation, including Merchant identification verification and due diligence with respect to Merchant’s facilities, equipment, inventory and any required business licenses/permits. ...

The Supreme Court asserted that the phrase “is probably the widest of any expression intended to convey some connection between two related subject matters”. [51] In addition, I find that the use of the word “pour” in the French version does not require a restrictive interpretation. ... 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.”). ...

These four individuals had previously not been directors of MMV; however, Paul Amirault had been an officer of MMV from 2004 to 2009 and a former shareholder of MMV. f) Prepping the Board and Officers and Settling the Debts [22]   In December 2010, MMV Financial signed indemnity agreements with each member of MMV’s board of directors, indemnifying them against all liabilities and costs in connection with their duties as a member of the board. [23]   On December 21, 2010, 7733704 Canada Inc. (“773”) was incorporated under the Canadian Business Corporations Act, RSC 1985, c. c-144 (the “ CBCA ”) and subscribed for 17 common shares (one less than the 18 shares previously outstanding) in MMV. 773 is a wholly owned subsidiary of MMV Financial. ... In 1919, the Income War Tax Act was amended to prohibit the deduction of losses that were not incurred in connection with the taxpayer’s “chief business, trade, profession or occupation” against income therefrom, and losses were not permitted to be carried forward or back [15]. ... [Emphasis added] [82]   Similarly, the Canadian Tax Reporter mentioned the following regarding these changes [23]: Section 27(5) was introduced in 1958 and was amended in 1963 to refer to control rather than to a stipulated percentage of shares in connection with acquisitions after June 13, 1963. ...

., has a “connexion, correspondence or association” [41] to) the production in Canada of potash. [83] The question, therefore, is whether a “sale or other disposition of” potash mined by the Appellant in Saskatchewan relates to the production of that potash. ... There is a direct and immediate connection between the production of potash and the subsequent sale or disposition of that potash. ... Investigations 25(1) When it is considered by the minister to be necessary for the purposes of this Act, the minister or any officer of the department authorized by the minister to do so may at any time enter upon any premises for the purposes of making enquiries and obtaining information relating to the administration of this Act, and for any of those purposes he may use all machinery, equipment, appliances and things as he considers necessary or expedient, and is entitled: (a) to be given free ingress and egress to, from and over all buildings and structures used in connection with the operation of any facility from, at or in which any scheduled minerals are produced, sold or otherwise disposed of, treated, processed or refined in any way, or any building or office, whether or not occupied by a taxpayer, at which any books or records pertaining to the production, sale or other disposition, treatment, processing or refining of any scheduled minerals are kept;... ...

The worker had also filed her income tax return reporting business income and claiming expenses incurred in connection with those activities. ... It clearly provided that the Appellant was an independent contractor, that there was no employer-employee relationship and that he was required to assume all promotional expenses incurred in connection with that activity. [229] I find that the level of control exercised by IA was primarily for monitoring purposes and quality control in the sale of its products. ... This would be consistent with articles 1425 and 1426 of the CcQ. [234] Having reviewed the objective reality of the workplace, I am unable to conclude that there was “a contract for employment” in accordance with Article 2085 of the CcQ since the Appellant had not agreed “to do work under the direction or control of another person”, namely IA. [235] On the contrary, I conclude that the Appellant was engaged in a “contract for enterprise” in accordance with Article 2099 of the CcQ, since he “was free to choose the means of performing the contract” and, in connection with such performance, there was “no relationship of subordination”. [236] The Court concludes that the Appellant was not engaged in insurable employment for the purpose of the EIA during the period in question. [237] For all the foregoing reasons, the appeal is dismissed without costs. ...