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First, in the financial statement which he filed in connection with her legal action (Exhibit T-1, Tab 6), he assigned values to certain properties which were allocated between him and Patricia in the Separation Agreement different from the values used in that agreement. ... In this connection it must be recalled that the total amount owing by the Appellant as of May 31st, 1986, under paragraph 3 of the 1983 Order was approximately $14,000. ...

McNeill’s political connections. There would be no problem getting the licence.” [38] With respect to the purchasing of C & C, it was as easy to purchase the company with the plane and there would be some tax saving. ... McNeill’s political connections. There would be no problem getting the licence.” ...

Fitzgerald had expressed concern about claims by individuals who had purchased memberships in the RV park, and he had stated that he did not want any connection with Enterprises. ... However, the connection between obtaining financial statements and discovering either financial difficulty or a failure to remit is a tenuous one, particularly since a private corporation such as Enterprises is not required to have audited financial statements [93] and unaudited financial statements can be manipulated by the person providing the information on which the statements are based. [106]    I am unable to conclude that the Appellant’s failure to obtain financial statements of Enterprises indicates that he ought to have known that Enterprises was in financial difficulty when all of the other objective circumstances at the time suggested otherwise. ...

The link in quantum and timing is very important because it locks in either a gain or a price. [87]          The Appellant cited Echo Bay Mines Ltd v Canada (TD), [1992] 3 FC 707, 92 DTC 6437 [Echo Bay], Placer Dome, supra, and Salada Foods Ltd v The Queen, [1974] CTC 201 (FCTD), 74 DTC 6171 (FCTD) [Salada Foods], as authorities that confirmed the requirement of an extremely close link between the purported hedge and the underlying asset or transaction in order to support a finding of a hedge for income tax purposes. [88]          More specifically, in Echo Bay, supra, the Federal Court of Appeal concluded that there was a sufficient inter-connection and integration with the taxpayer’s business, i.e. the production of silver, such that the gain from the closing out of the forward sales contract was considered income from that business. ... I cannot find any connection between the amount borrowed under the Loan and the entering into, and the settlement of, the Forward Contract. [107]      In the present case, there is no particular transaction that occurred around the time Mr.  ...

The evidence is that Francesco executed a guarantee in favour of the vendor in connection with the acquisition of the Vancouver Canucks’ operations and there is further evidence that as between the brothers, any guarantees given by any brother would be the responsibility of all three. ... I note that since I found the predominant or principal purpose of the allocation agreement to be a reduction in tax, the Appellants’ arguments that I should distinguish the cases the Respondent relied upon in connection with subsection 103(1), including XCO above and Penn West above on the basis tax was the sole motivation to the ephemeral participation of a new partner and involved amendments to the allocation agreement to affect same are not convincing. ...

., a non-arm’s length Barbados international business corporation (“NewAgco Barbados”) in the years in question in connection with the sale by NewAgco Barbados directly to Canadian farmer-users of a glyphosate-based herbicide (“ClearOut”) (being a generic version of Bayer-Monsanto’s RoundUp). [3]   In reassessing AgraCity for its 2007 and 2008 taxation years [1] the Canada Revenue Agency (“CRA”) relied upon the transfer pricing rules in paragraphs 247(2)(a) and (c) of the Income Tax Act (the “ Act ”) and re-allocated an amount equal to all of NewAgco Barbados’ profits from these sales activities to the income of AgraCity. [4]   In its Amended Reply in this Court the Respondent’s position is that: 1. ... One of the PMRA’s key concerns was that FNA only be promoting ClearOut’s availability under the OUI program and offering its services to members in connection with that, and that FNA not be offering ClearOut for sale in Canada. [54]   In 2005 FNA recorded and reported in Canada its membership fee revenues and AgraCity recorded and reported in Canada its revenues under the Services Agreement with NewAgco US. ...

., or any affiliate or subsidiary designated by it, whereby it will, because of its knowledge of the property, have the right to act as leasing agent, and when applicable, as sales agent for the limited partnership and to have any listing, whether for lease or sale, in connection therewith, in the event of leasing of available space or any sale of the Swansea Shopping Centre Project comprising the business of the limited partnership and shall be entitled to payment in the amount and on the terms usually paid to independent leasing or sales agents operating in the city of Toronto performing similar functions. 10.01 Each subscribing limited partner shall provide by way of initial capital contribution, for each unit acquired, the sum of $100,000, the sum of $12,500 which was delivered at the time of delivery of the subscription and the balance by cash or certified cheque on or before April 15, 1986. 10.02 Each subscribing limited partner shall further provide by way of capital contribution, for each unit acquired, the further sum of $100,000 such amount to be paid by way of delivery of a promissory note issued in favour of H.L. ... We request that our concerns are passed on as soon as possible to those responsible for the excavation and that Consumers’ Gas be notified so that they can inspect the connection. ...

Ted Cohen who personally provided Tangerine Inc. with the services that the appellant presumably agreed to provide; [denied as written: his wife also provided services in this connection (trans., page 31)] (f) during the years at issue, Mr. ... Cohen directly with a car and reimbursed certain expenses incurred by him in connection with his work, such as travel and representation expenses; [denied as written: the said car was used by several persons; further, while some expenses were reimbursed, most were paid by Tedco (Exhibit A-1, page 7)] (i) from May 1, 1983 to April 30, 1985, Mr. ...

A 10-inch sewer connection was under construction to Hirst Street at Pym Road to serve future subdivision of District Lot 16, this subject. ... The subject has an actual water connection. An examination of the sales from 1968 indicates a constant and increasing demand for lots in the area of the subject. ...

Electrical cable and connections not in excess of 100 feet from distribution board. ... The amendment stated the following: By this modification the parties agree that Radisson is not a party anymore to the plant agreement and Eldorado hereby acknowledges that as of this date no payments by Rupert are due and that Radisson has no obligations of whatever nature in connection with the plant agreement. ...