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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. ...

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. ...