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He was prohibited from acting directly or indirectly as an appraiser, promoter, broker or consultant in connection with gifts of works of art to non-profit organizations, such as charities, and in particular museums and fabriques. ... Demers also made a connection between invoices from the Galerie des Maîtres Anciens and Univers du Rail Inc. ...

He was prohibited from acting directly or indirectly as an appraiser, promoter, broker or consultant in connection with gifts of works of art to non-profit organizations, such as charities, museums and fabriques. ... Demers also made a connection between invoices from the Galerie des Maîtres Anciens and Univers du Rail Inc. ...

The context for the purpose of the interpretation of a treaty shall comprise, in addition to the text, including its preamble and annexes: (a) any agreement relating to the treaty which was made between all the parties in connexion with the conclusion of the treaty; (b) any instrument which was made by one or more parties in connexion with the conclusion of the treaty and accepted by the other parties as an instrument related to the treaty.               3. ...

In that case, even though there was a sham and it was contended that the operation had no real business connection in Canada, the Court found that Gurd's Products was in fact carrying on business in Canada and one could not disregard the facts in support of the company's position to the contrary. [150]        Counsel referred to London Life Insurance Company, supra, and argued that one must look to the entire facts of the business and not one aspect of it only. In that case the Court considered the "cumulative effect" of a number of factors (including the place where profits were generated and where the expenses were incurred by the taxpayer in connection with his alleged business). ...

Section 18 – Income Tax Act   [44] Subsection 18(1) of the Act states in part as follows:   18.(1) In computing the income of a taxpayer from a business or property no deduction shall be made in respect of   (a) an outlay or expense except to the extent that it was made or incurred by the taxpayer for the purpose of gaining or producing income from the business or property;   …   (h) personal or living expenses of the taxpayer, other than travel expenses incurred by the taxpayer while away from home in the course of carrying on the taxpayer’s business;   “Personal or living expenses” under subsection 248(1) are defined as follows:   “Personal or living expenses” includes   (a) the expenses of properties maintained by any person for the use or benefit of the taxpayer or any person connected with the taxpayer by blood relationship, marriage or common-law partnership or adoption, and not maintained in connection with a business carried on for profit or with a reasonable expectation of profit, (b) the expenses, premiums or other costs of a policy of insurance, annuity contract or other like contract if the proceeds of the policy or contract are payable to or for the benefit of the taxpayer or a person connected with the taxpayer by blood relationship, marriage or common-law partnership or adoption, and             (c) expenses of properties maintained by an estate or trust for the benefit of the taxpayer as one of the beneficiaries;   [45] In Symes v. ... Miller devoted substantial time to Aircraft related activities that had no business purpose and no connection with the Appellant’s management duties; z)      Mr. ...

(“RBC Dominion”) to assist the Independent Committee in its mandate and to provide a fairness opinion in connection with any proposal to acquire the Residual Assets.   20. ... His client, Balaclava, had instructed him that it was prepared to accommodate Husky’s desire that Mohawk Canada not pay taxes in connection with the disposition of the Residual Assets provided that Balaclava’s commercial objectives were not prejudiced thereby. ...

In this connection, LeBel J.'s words in Blencoe, supra, at para. 188 are apposite: We must remember though that s. 7 expresses some of the basic values of the Charter. ... For the purposes of paragraph 118.2(2)(m) of the Act, a device or equipment is prescribed if it is a (a) wig made to order for an individual who has suffered abnormal hair loss owing to disease, medical treatment or accident; (b) needle or syringe designed to be used for the purpose of giving an injection; (c) device or equipment, including a replacement part, designed exclusively for use by an individual suffering from a severe chronic respiratory ailment or a severe chronic immune system disregulation, but not including an air conditioner, humidifier, dehumidifier, heat pump or heat or air exchanger; (c.1) air or water filter or purifier for use by an individual who is suffering from a severe chronic respiratory ailment or a severe chronic immune system disregulation to cope with or overcome that ailment or disregulation; (c.2) electric or sealed combustion furnace acquired to replace a furnace that is neither an electric furnace nor a sealed combustion furnace, where the replacement is necessary solely because of a severe chronic respiratory ailment or a severe chronic immune system disregulation; (c.3) air conditioner acquired for use by an individual to cope with the individual's severe chronic ailment, disease or disorder, to the extent of the lesser of $1,000 and 50% of the amount paid for the air conditioner; (d) device or equipment designed to pace or monitor the heart of an individual who suffers from heart disease; (e) orthopaedic shoe or boot or an insert for a shoe or boot made to order for an individual in accordance with a prescription to overcome a physical disability of the individual; (f) power-operated guided chair installation, for an individual, that is designed to be used solely in a stairway; (g) mechanical device or equipment designed to be used to assist an individual to enter or leave a bathtub or shower or to get on or off a toilet; (h) hospital bed including such attachments thereto as may have been included in a prescription therefor; (i) device that is designed to assist an individual in walking where the individual has a mobility impairment; (j) external breast prosthesis that is required because of a mastectomy; (k) teletypewriter or similar device, including a telephone ringing indicator, that enables a deaf or mute individual to make and receive telephone calls; (l) optical scanner or similar device designed to be used by a blind individual to enable him to read print; (m) power-operated lift or transportation equipment designed exclusively for use by, or for, a disabled individual to allow the individual access to different areas of a building or to assist the individual to gain access to a vehicle or to place the individual's wheelchair in or on a vehicle; (n) device designed exclusively to enable an individual with a mobility impairment to operate a vehicle; (o) device or equipment, including a synthetic speech system, braille printer and large print-on-screen device, designed exclusively to be used by a blind individual in the operation of a computer; (p) electronic speech synthesizer that enables a mute individual to communicate by use of a portable keyboard; (q) device to decode special television signals to permit the script of a program to be visually displayed; (q.1) a visual or vibratory signalling device, including a visual fire alarm indicator, for an individual with a hearing impairment; (r) device designed to be attached to infants diagnosed as being prone to sudden infant death syndrome in order to sound an alarm if the infant ceases to breathe; (s) infusion pump, including disposable peripherals, used in the treatment of diabetes or a device designed to enable a diabetic to measure the diabetic's blood sugar level; (t) electronic or computerized environmental control system designed exclusively for the use of an individual with a severe and prolonged mobility restriction; (u) extremity pump or elastic support hose designed exclusively to relieve swelling caused by chronic lymphedema; (v) inductive coupling osteogenesis stimulator for treating non-union of fractures or aiding in bone fusion; and (w) talking textbook prescribed by a medical practitioner for use by an individual with a perceptual disability, in connection with the individual's enrolment at an educational institution in Canada. (4)      Excerpts from Federal Budget, Notices of Ways and Means Motion, February 23, 2005 (11) That, for the 2005 and subsequent taxation years, there be added to the list of expenses eligible for the medical expense tax credit, amounts paid (a) to purchase, operate and maintain phototherapy equipment for the treatment of psoriasis or other skin disorders; (b) to operate and maintain an oxygen concentrator; (c) for deaf-blind intervening services used by an individual who is both blind and profoundly deaf (if paid to persons engaged in the business of providing such services); (d) for reading services used by an individual who is blind or who has a severe learning disability, if the need for the service is certified in writing by a medical practitioner and paid to persons engaged in the business of providing such services; (e) for drugs or medical devices obtained under Health Canada's Special Access Programme; (f) for the purchase of medical marihuana or marihuana seeds, from Health Canada, for use by a patient who is authorized to possess marihuana for medical purposes under the Marihuana Medical Access Regulations (MMAR) or who holds an Exemption for possession under Section 56 of the Controlled Drugs and Substances Act (CDSA); and (g) for the purchase of medical marihuana, for use by a patient who is authorized to possess marihuana for medical purposes under the MMAR or who holds an Exemption for possession under Section 56 of the CDSA, from an individual who possesses a Designated-person Production Licence under the MMAR to cultivate or produce marihuana for medical purposes on behalf of that patient or who holds a designated person Exemption for cultivation or production under Section 56 of the CDSA to cultivate or produce marihuana for medical purposes on behalf of that patient. (12) That, for expenses incurred after February 22, 2005, the provisions of the Act that include as an eligible medical expense reasonable expenses relating to renovations or alterations to a dwelling of a patient who lacks normal physical development or has a severe and prolonged mobility impairment to enable the patient to gain access to, or to be mobile or functional within, the dwelling, be amended to require that such expenses (a) must be of a type that would not typically be incurred by persons who have normal physical development or who do not have a severe and prolonged mobility impairment; and (b) must not be of a type that would typically be expected to increase the value of the dwelling. ...

At page 29, summarizing seven principles dealing with presumptions, Cory J. wrote as principle III: "Even if a rational connection exists between the established fact and the fact to be presumed, this would be insufficient to make valid a presumption requiring the accused to disprove an element of the offence." [31]     This principle applies in my view to the impugned provisions in the case at bar which require the Appellant, by virtue of his gender, to disprove or rebut a presumed fact even if there is a rational connection between the established facts and the presumed fact. ...

"Rob" appears frequently in both the oral and documentary evidence, particularly in connection with the transactions with Indians. [43]     It is, I think, a fair conclusion on all of the evidence that "Rob" is Robert Robichaud, the employee of Orly and that he was very much involved in the part of the overall transactions that had to do with the sales of the vehicles in question here to Indians and from this I conclude that so was Orly. [44]     The other employee, Shawn McGovern, testified that he dealt with the various persons shown as vendors. ... I do not find that high degree of negligence in connection with the misstatements of business income. ...

No worker ever charged Scott any GST in connection with provision of services since none earned in excess of $30,000 per year and was not required to register as a supplier. ... The evidence established the workers were required to perform their duties personally and were not required to provide any additional tools or equipment or personnel in order to ensure ongoing sales activity within the store. [29]     The workers located in the Victoria area- and Dhillon in Duncan- purchased their own cell phones- at cost- but paid a licensing fee and GST and incurred certain additional expenses in connection with sales activity although not in respect of in-store sales. ...