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M.N.R. summarized the principles that apply with respect to disclosure to accountants as follows:   Applying these principles, as I understand them, to materials prepared by accountants, in a general way, it seems to me   (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. [19]   [72]         Counsel for the Appellant argued that the solicitor-client privilege extended to communications with PWC Australia on the basis that PWC Australia’s input was necessary to the provision of legal advice by counsel. ...

The Proposal   1.1               TSI will at its own expense:   (a)        file, seek creditor approval of and Ontario Superior Court of Justice, in Bankruptcy and Insolvency (the "Court"), approval of (including the required order of the Court as authorized under section 191 of the Canada Business Corporations Act (the "CBCA"), and   …   1.3       Upon implementation of the Proposal and completion of this Agreement:   (a)        except as expressly agreed in writing by NRT, TSI will have no liabilities of any nature, kind or priority whatsoever, including any liabilities to which TSI may become subject on or after the filing of the Proposal (collectively, "Liabilities"), and shall own the following property and assets:   (i)                  the property and assets (including books and records) described in the attached Schedule "C"; and   (ii)                the full benefit of and entitlement to the use without restriction of non-capital loss carryforwards for income tax purposes in the amount of at least $15 million measured as if TSI had a year-end for tax purposes immediately prior to the completion of the Transaction and after such tax loss carryforwards have been reduced or otherwise adjusted by any debt forgiveness or other matters arising from the Transaction including the Proposal (collectively, all such tax loss carryforwards being the "Tax Losses");   …   7.2       The Consideration shall be used solely and exclusively for the purposes of:   (a)        payment of TSI’s legal, consulting and Trustee’s fees and disbursements in connection with this Agreement, the Proposal, the BIA proceedings and the Transaction, not to exceed $200,000; and   (b)        payment by the Trustee of the distributions to creditors of TSI required under the Proposal ...

The legal expenses incurred by the Appellant in connection with the Action were fully deducted on a current basis on income in the year incurred for both accounting and income tax purposes. 18.            ...

Nor, in my view, does Emerson (4.03.3(7)) apply, because the source of income had completely disappeared, but there was no other source having any connection with the loan as there is here: in the present ease, while the source of income derived from the loan had disappeared, the first source, which had moreover made the loan possible, still exists, and again it is as a result of that first source that the appellants were able to continue to pay the loan, the condition sine qua non for preserving that source. 4.04.2(3)(a) Can we not say that, beginning on June 23, 1983, there was a change of source? ...

Analysis [29]     The question at issue is the following: can the Appellant deduct his travel expenses and his motor vehicle expenses in connection with his travel between his residence and the various docks in the Port of Montreal? ...

The Security Company agreed to sell and transfer to the Premier Company, and the Premier Company agreed to purchase from the Security Company, the whole of the assets and undertaking of the Security Company as a going concern, including the goodwill of its business, and the same was so described in the Agreement as to include any reserves or undistributed profits to which the Security Company was entitled in connection with its business.... ...

  [18]         The Respondent replies to TELUS’ position vis-à-vis the ITCs in connection with the mail-in coupons by arguing the mail-in coupon was not a coupon as defined, but a rebate on the price of the phone, which was not supplied by TELUS and therefore could not be accepted as consideration for that supply. ...

Any business connection is remote. [85]     The Shareholders also dispute the income inclusion on procedural grounds. ...

In its Amended Notice of Appeal, Magicuts submitted that USMagicuts operated as its agent in connection with the business carried on by Magicuts in the United States and, therefore, losses incurred by USMagicuts were losses incurred by Magicuts. ...

(c) Thirdly to pay all maintenance, realty taxes, and operating expenses in connection with the company. ...