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If he does not do so, the rules of subsection 152(4) apply. 4.03.2(2) In connection with subsection 160(2), counsel for the appellant referred to Thorsteinson (para. 4.02(2)), in which Taylor, J., then a member of the Tax Review Board, said at 2419: Both counsel proposed that while section 160 of the Act provided a method for the Minister to collect tax, the only mechanism open to him in order to do so was to issue an assessment under subsection (2) which reads: The Minister may at any time assess a transferee in respect of any amount payable by virtue of this section and the provisions of this Divsion are applicable mutatis mutandis in respect of an assessment made under this section as though it had been made under section 152. ...

I shall cite it in full: ARTICLE NINE In addition to all powers conferred by law, I give my Executors and Trustees the right and power, without the intervention or consent of the beneficiaries herein named: (a) To retain investments and to invest and reinvest the monies of the Estate as they may think proper without being limited to investments permitted to Trustees by law, and from time to time in their discretion to sell, alter and vary such investments, and to participate in the amalgamation, reorganization or recapitalization of any corporation or firm in which my Estate may have any share or interest; (b) To hold investments in their own name or that of a nominee, with or without the addition of words indicating that they hold them in a fiduciary Capacity; (c) To sell, lease, hypothecate, pledge, release, alienate, exchange, abandon and otherwise dispose of all property of my Estate, both moveable and immoveable, in such manner as they may see fit, and also to borrow money for, or to advance money to, the Estate; (d) To continue, or in their discretion to discontinue and wind up any business, undertaking, guarantee or obligation in which I may be concerned, and to appoint attorneys or representatives to act for them in connection with any such business or undertaking or any other matters concerning my Estate; (e) To release any property affected by mortgage or hypothec, in whole or in part, and to compromise and waive any claims at any time due to or by my Estate for any consideration or without consideration and upon such terms and conditions as they may deem advisable; (f) To make such capital and revenue expenditures as they may deem advisable upon the repairing, improving or rebuilding of any property of my Estate; (g) To determine and distinguish capital from revenue and to credit or charge receipts and disbursements to capital or revenue of my Estate in such proportions and amounts as they may think proper; (h) To make any partitions of my Estate in such manner as they may deem best without any process of law even though some of the beneficiaries may be minors or otherwise incapable, and also to settle any shares in my Estate either by paying the same in cash or by conveying to the party entitled thereto such investments belonging to my Estate as they may deem fair and sufficient; (i) To perform any act authorized by this my Will without having to obtain judicial authority, even though some of the necessary parties to such act are incapable persons, and without limiting the generality of the foregoing, to do all acts which a person of full capacity could do if owner of the assets comprising my Estate. ...

He finally persuaded the Ontario government to provide a $300,000 grant to the brothers Thompson in connection with setting up “Cabinets” resulting in the transactions under review in this appeal. ...

. — Report and testimony of expert witness, E Lloyd Saunders, California Attorney — Reese v MNR, 55 DTC 489 per Fisher WS at page 490 From a study of the California law other than that cited to the Board at the hearing it appears that, prior to an amendment which became effective on and after the 29th day of July 1927, the wife, under the decisions of the California Courts in connection with community property laws of the State was held to have only an “expectancy” and not a present, vested in equal interests with her husband in the community property. ...

The learned trial judge held that John Stradwick, Jr, W L Stradwick and H D McGilvery, who collectively owned more than 50% of the shares of Stradwick’s Limited, had at all material times a sufficient common connection as to be in a position to exercise control over Stradwick’s Limited and therefore constituted a “group of persons” within the meaning of subsection (4) of section 39 of the Income Tax Act (66 DTC 5373). ...

The issue in the present case relates to the computation of the small business deduction under Section 125 of the Income Tax Act in connection with the question as to whether, as alleged in the assessments and notification, the taxpayer was associated with Falcon Luggage Inc within the meaning of the provisions of Section 256 of the Income Tax Act. 2. ...

“by virtue of”... require a strong causal connection. I find little or no difference between the meanings of the phrases “because of’, “as a consequence of’ and “by virtue of’. ...

She did not question the origin of the refund or consider it might have a connection to the business loss. ...

Burden of Cassels, Brock. 5 ^Exhibit A-3, Tab 29. 6 ^The settlement agreement specifically indicates that both 560233 and the Appellant ob- tained independent legal advice in connection with its terms and effect. ...

E-15, as amended (the “ ETA ”) for the reporting periods of October 1, 2011 to December 31, 2011; October 10, 2012 to December 31, 2012 and October 10, 2013 to December 31, 2013. [3] Since both of these appeals have significant factual, legal and temporal connections, they were heard together on common evidence. ...