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And do you know, can you tell whether that relates to income that she gained in connection with ICS? ...

The relevant portions of the definition for the purposes of these appeals are as follows: “commercial activity” of a person means (a) a business carried on by the person... except to the extent to which the business involves the making of exempt supplies by the person,... and (c) the making of a supply (other than an exempt supply) by the person of real property of the person, including anything done by the person in the course of or in connection with the making of the supply. ...

There can be no doubt, on a reading of s. 90(1)(b), that it would not apply to any personal property that an Indian band might acquire in connection with an ordinary commercial agreement with a private concern.  ...

If I had to set out a test for verifying whether a confidential document has a semblance of relevance, I would favour the genuine connection test. ...

That business does not have any connection to his work at L.A. Music. ...

ANNEX A 118.3(1) Credit for mental or physical impairment — Where (a) an individual has one or more severe and prolonged impairments in physical or mental functions, (a.1) the effects of the impairment or impairments are such that the individual’s ability to perform more than one basic activity of daily living is significantly restricted where the cumulative effect of those restrictions is equivalent to having a marked restriction in the ability to perform a basic activity of daily living or are such that the individual’s ability to perform a basic activity of daily living is markedly restricted or would be markedly restricted but for therapy that (i) is essential to sustain a vital function of the individual, (ii) is required to be administered at least three times each week for a total duration averaging not less than 14 hours a week, and (iii) cannot reasonably be expected to be of significant benefit to persons who are not so impaired, (a.2) in the case of an impairment in physical or mental functions the effects of which are such that the individual’s ability to perform a single basic activity of daily living is markedly restricted or would be so restricted but for therapy referred to in paragraph (a.1), a medical practitioner has certified in prescribed form that the impairment is a severe and prolonged impairment in physical or mental functions the effects of which are such that the individual’s ability to perform a basic activity of daily living is markedly restricted or would be markedly restricted, but for therapy referred to in paragraph (a.1), where the medical practitioner is a medical doctor or, in the case of (i) a sight impairment, an optometrist, (ii) a speech impairment, a speech-language pathologist, (iii) a hearing impairment, an audiologist, (iv) an impairment with respect to an individual’s ability in feeding or dressing themself, an occupational therapist, (v) an impairment with respect to an individual’s ability in walking, an occupational therapist, or after February 22, 2005, a physiotherapist, and (vi) an impairment with respect to an individual’s ability in mental functions necessary for everyday life, a psychologist, (a.3) in the case of one or more impairments in physical or mental functions the effects of which are such that the individual’s ability to perform more than one basic activity of daily living is significantly restricted, a medical practitioner has certified in prescribed form that the impairment or impairments are severe and prolonged impairments in physical or mental functions the effects of which are such that the individual’s ability to perform more than one basic activity of daily living is significantly restricted and that the cumulative effect of those restrictions is equivalent to having a marked restriction in the ability to perform a single basic activity of daily living, where the medical practitioner is, in the case of (i) an impairment with respect to the individual’s ability in feeding or dressing themself, or in walking, a medical doctor or an occupational therapist, and (ii) in the case of any other impairment, a medical doctor, (b) the individual has filed for a taxation year with the Minister the certificate described in paragraph (a.2) or (a.3), and (c) no amount in respect of remuneration for an attendant or care in a nursing home, in respect of the individual, is included in calculating a deduction under section 118.2 (otherwise than because of paragraph 118.2(2)(b.1)) for the year by the individual or by any other person, there may be deducted in computing the individual’s tax payable under this Part for the year the amount determined by the formula A × (B + C) where A is the appropriate percentage for the year, B is $6,000, and C is (a) where the individual has not attained the age of 18 years before the end of the year, the amount, if any, by which (i) $3,500 exceeds (ii) the amount, if any, by which (A) the total of all amounts each of which is an amount paid in the year for the care or supervision of the individual and included in computing a deduction under section 63, 64 or 118.2 for a taxation year exceeds (B) $2,050, and (b) in any other case, zero. (1.1) Time spent on therapy — For the purpose of paragraph 118.3(1)(a.1), in determining whether therapy is required to be administered at least three times each week for a total duration averaging not less than an average of 14 hours a week, the time spent on administering therapy (a) includes only time spent on activities that require the individual to take time away from normal everyday activities in order to receive the therapy; (b) in the case of therapy that requires a regular dosage of medication that is required to be adjusted on a daily basis, includes (subject to paragraph (d)) time spent on activities that are directly related to the determination of the dosage of the medication; (c) in the case of a child who is unable to perform the activities related to the administration of the therapy as a result of the child’s age, includes the time, if any, spent by the child’s primary caregivers performing or supervising those activities for the child; and (d) does not include time spent on activities related to dietary or exercise restrictions or regimes (even if these restrictions or regimes are a factor in determining the daily dosage of medication), travel time, medical appointments, shopping for medication or recuperation after therapy. (2) Dependant having impairment — Where (a) an individual has, in respect of a person (other than a person in respect of whom the person’s spouse or common-law partner deducts for a taxation year an amount under section 118 or 118.8) who is resident in Canada at any time in the year and who is entitled to deduct an amount under subsection (1) for the year, (i) claimed for the year a deduction under subsection 118(1) because of (A) paragraph (b) of the description of B in that subsection, or (B) paragraph (c.1) or (d) of that description where the person is a parent, grandparent, child, grandchild, brother, sister, aunt, uncle, nephew or niece of the individual, or of the individual’s spouse or common-law partner, or (ii) could have claimed for the year a deduction referred to in subparagraph (i) in respect of the person if (A) the person had no income for the year and had attained the age of 18 years before the end of the year, and (B) in the case of a deduction referred to in clause (i)(A), the individual were not married or not in a common-law partnership, and (b) no amount in respect of remuneration for an attendant, or care in a nursing home, because of that person’s mental or physical impairment, is included in calculating a deduction under section 118.2 (otherwise than under paragraph 118.2(2)(b.1)) for the year by the individual or by any other person, there may be deducted, for the purpose of computing the tax payable under this Part by the individual for the year, the amount, if any, by which (c) the amount deductible under subsection (1) in computing that person’s tax payable under this Part for the year exceeds (d) the amount of that person’s tax payable under this Part for the year computed before any deductions under this Division (other than under sections 118 to 118.07 and 118.7). (3) Partial dependency — Where more than one individual is entitled to deduct an amount under subsection (2) for a taxation year in respect of the same person, the total of all amounts so deductible for the year shall not exceed the maximum amount that would be deductible under that subsection for the year by an individual in respect of that person if that individual were the only individual entitled to deduct an amount under that subsection in respect of that person, and where the individuals cannot agree as to what portion of the amount each can deduct, the Minister may fix the portions. (4) Additional information — Where a claim under this section or under section 118.8 is made in respect of an individual’s impairment (a) if the Minister requests in writing information with respect to the individual’s impairment, its effects on the individual and, where applicable, the therapy referred to in paragraph (1)(a.1) that is required to be administered, from any person referred to in subsection (1) or (2) or section 118.8 in connection with such a claim, that person shall provide the information so requested to the Minister in writing; and (b) if the information referred to in paragraph (a) is provided by a person referred to in paragraph (1)(a.2) or (a.3), the information so provided is deemed to be included in a certificate in prescribed form. 118.4(1) Nature of impairment — For the purposes of subsection 6(16), sections 118.2 and 118.3 and this subsection, (a) an impairment is prolonged where it has lasted, or can reasonably be expected to last, for a continuous period of at least 12 months; (b) an individual’s ability to perform a basic activity of daily living is markedly restricted only where all or substantially all of the time, even with therapy and the use of appropriate devices and medication, the individual is blind or is unable (or requires an inordinate amount of time) to perform a basic activity of daily living; (b.1) an individual is considered to have the equivalent of a marked restriction in a basic activity of daily living only where all or substantially all of the time, even with therapy and the use of appropriate devices and medication, the individual’s ability to perform more than one basic activity of daily living (including for this purpose, the ability to see) is significantly restricted, and the cumulative effect of those restrictions is tantamount to the individual’s ability to perform a basic activity of daily living being markedly restricted; (c) a basic activity of daily living in relation to an individual means (i) mental functions necessary for everyday life, (ii) feeding oneself or dressing oneself, (iii) speaking so as to be understood, in a quiet setting, by another person familiar with the individual, (iv) hearing so as to understand, in a quiet setting, another person familiar with the individual, (v) eliminating (bowel or bladder functions), or (vi) walking; (c.1) mental functions necessary for everyday life include (i) memory, (ii) problem solving, goal-setting and judgement (taken together), and (iii) adaptive functioning; (d) for greater certainty, no other activity, including working, housekeeping or a social or recreational activity, shall be considered as a basic activity of daily living; (e) feeding oneself does not include (i) any of the activities of identifying, finding, shopping for or otherwise procuring food, or (ii) the activity of preparing food to the extent that the time associated with the activity would not have been necessary in the absence of a dietary restriction or regime; and (f) dressing oneself does not include any of the activities of identifying, finding, shopping for or otherwise procuring clothing. (2) Reference to medical practitioners, etc. — For the purposes of sections 63, 64, 118.2, 118.3 and 118.6, a reference to an audiologist, dentist, medical doctor, medical practitioner, nurse, occupational therapist, optometrist, pharmacist, physiotherapist, psychologist, or speech-language pathologist is a reference to a person authorized to practise as such, (a) where the reference is used in respect of a service rendered to a taxpayer, pursuant to the laws of the jurisdiction in which the service is rendered; (b) where the reference is used in respect of a certificate issued by the person in respect of a taxpayer, pursuant to the laws of the jurisdiction in which the taxpayer resides or of a province; and (c) where the reference is used in respect of a prescription issued by the person for property to be provided to or for the use of a taxpayer, pursuant to the laws of the jurisdiction in which the taxpayer resides, of a province or of the jurisdiction in which the property is provided. ...

Semenov apparently told the CRA, [65] perhaps there was a connection between those cheques and the Subject Deposits in the amounts of $7,090 and $5,900 (totalling $12,990) made on January 13, 2011 and June 7, 2011 respectively to the BMO joint account. [66] During his examination-in-chief, Mr. ...

This report has been prepared for submission in connection with your Transitional New Housing Rebate claim pursuant to section 256.21 of the Excise Tax Act and the Regulations relating thereto. ...

Pearlman thought the first concern was cleared up by Graham Turner, a tax lawyer who provided a legal opinion in connection with the Artistic Program and the second concern was resolved by obtaining appraisals from two independent appraisers. [20]   Subsequently, the Artistic Program kicked off on a verbal agreement or mutual understanding between Sloan and Artistic’s principals that Artistic would act as Sloan’s agents in promoting the Artistic Program to Canadian investors and would earn a commission on any art sold. ...

Canada held that “ simple ownership of a mathematical majority of shares by a random aggregation of shareholders in a widely held corporation … without a common connection does not constitute de jure control as that term has been defined in the case law.” [11]   [106]   Subsection 111(5) is part of group of specific rules in subsections 111(4) to (5.3) that limit the carry-forward of non-capital losses, net capital losses, farm losses and unrealized losses on capital, depreciable and eligible capital property owned by the corporation and on doubtful debts. ...