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The connections he had with the other investors were through Mr. Arbic who served basically as a phone booth among everyone. [36]     The witness relates that he had previously worked on a volunteer basis for Consuform, perhaps in 1991. ...

In this connection we refer to the decision of this Court in H.M. v. Placer Dome Inc.}, [1] decided after the trial judgment in the present case. ...

The provision has four elements: (1) the amount must be paid in the year or be payable in the year in which it is sought to be deducted; (2) the amount must be paid pursuant to a legal obligation to pay interest on borrowed money; (3) the borrowed money must be used for the purpose of earning non-exempt income from a business or property; and (4) the amount must be reasonable, as assessed by reference to the first three requirements. [38]   [85]         The only issue before the Court is whether the approximately $7,550,000 that the Appellant borrowed from the Bank of Montreal in 2007 in connection with the redemption of the Subject Shares  was used for the purpose of earning non-exempt income from a business or property ...

In his 1999 income tax return, the Appellant Chartier reported a taxable capital gain of $239,321 from the disposition of his CFCDN Class D shares and claimed a deduction equal to that amount under subsection 110.6(2.1) of the ITA in connection with a purported disposition of qualified small business corporation shares.   14.       ...

    [2]      The Appellants claimed business losses and investment tax credits in connection with their investments in two partnerships: E.C.T. ...

There was no evidence to support the assertion that the connection between the Appellants and NFL as buyer was artificial. [49]          There was evidence from Shayne McDonald that there are other fish buyers in the Province who are not processors and who operate exactly like NFL. [50]          I conclude that in 2003 and 2004, the debtor was NFL and it was located on the Reserve. ...

Imasco further agrees and represents that the board of directors of Imasco will also resolve and will authorize and direct Imasco to, subject to the receipt of any necessary regulatory and stock exchange approvals, cause the vesting of option entitlements under its employee stock option plan to accelerate prior to the completion of the Reorganization, such that all outstanding options to acquire Imasco Shares become exercisable prior to the completion of the Reorganization, and to arrange for all Imasco Shares that are fully paid thereunder to be distributed to those persons entitled thereto so as to be able to be acquired by Bidco in connection with the Going Private Transaction and to thereafter satisfy all other obligations of Imasco under such plan.            ...

Harris explained that it was "[n]o longer sufficient that an outlay be incurred 'for the purpose of earning the income', as the statute required; to be deductible, the outlay also must have been incurred as part of and in immediate connection, in both time and result, with the trading aspects of the business operations". [18] [37]          In 1948 The Income Tax Act [19] (" 1948 Act ") did away with the requirement that "a deduction shall not be allowed in respect of disbursements or expenses not wholly, exclusively and necessarily" incurred for the purpose of earning income. ...

Minister of National Revenue, 69 DTC 5278, where he held, at page 5283: (a) that no communication, statement or other material made or prepared by an accountant as such for a business man falls within the privilege unless it was prepared by the accountant as a result of a request by the business man's lawyer to be used in connection with litigation, existing or apprehended; and (b) that, where an accountant is used as a representative, or one of a group of representatives, for the purpose of placing a factual situation or a problem before a lawyer to obtain legal advice or legal assistance, the fact that he is an accountant, or that he uses his knowledge and skill as an accountant in carrying out such task, does not make the communications that he makes, or participates in making, as such a representative, any the less communications from the principal, who is the client, to the lawyer; and similarly, communications received by such a representative from a lawyer whose advice has been so sought are none the less communications from the lawyer to the client. [14]     As for communications between lawyers and other third parties, it is well-established law that these will be privileged only where the third party is found to be an agent of the lawyer or client, or where the lawyer requests the third party's assistance in respect of real or contemplated litigation, as in the case of an expert witness. ...

It has to do with the deductibility of certain expenses or losses incurred by him in connection with a vessel which he intended to use in a fishing business. ...