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Convention are in agreement that it cannot be construed in a manner that prohibits the application of domestic anti-abuse rules to residents of the other contracting state, whether they are applied in the context of domestic legislation alone, or in connection with an avoidance scheme that depends upon an abuse of provisions of the Income Tax Act coupled with the U.S. ...

Finally, his advice was inconsistent with the factual reality that the Appellant transferred only the legal title to the properties to the corporations that acted as her exclusive agents in connection with those properties and the business ...

Work expended on or in connection with the property realized. There was none unless one includes the insertion of additional assets into CBL (the drag line) and the removal from CBL of six leases that CC did not want. 5. ...

Where a loan is made for the purpose of earning income through the payment of dividends, this connection is sufficient to satisfy the purpose requirement of subparagraph 40(2)(g)(ii) ...

I do not find that high degree of negligence in connection with the misstatements of business income. ...

This case law, based on the search for a certain connection between the disputed transaction and the business's current activities, is quite relevant in identifying the profits made by the business. ...

The choice allowed under subsection 73(1) of the Act was made in connection with the sale of the first block of shares so as to produce a capital gain for Mr.  ...

The Queen, 2000 DTC 2230, I used the expression de facto director in connection with the sole owner and controller of a construction company. ...

He did not offer any compelling evidence showing that he was unable, for reasons related to his origin or language, to understand the consequences of his waiver or that tax officials tried to mislead him, threaten him or apply undue pressure in connection with the waiver. ...

These other persons appear to have had less connection to Pi Media in terms of regularity of service and interaction with Pi Media’s creative team. ...