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He is a consultant specializing in assisting individual Indians, Indian bands, Indian groups and Indian-controlled corporations in obtaining government funding in connection with their activities and their businesses. ... The term "permanent establishment" is defined in the tax treaties between Canada and other countries in connection with provisions directed toward avoiding the taxation of the same income in two jurisdictions. ... It is also respectively defined in regulations 400 and 2600 of the Income Tax Regulations in connection with the determination of taxable income earned by a corporation in the year in a province for purposes of the deduction under Section 124 of the Income Tax Act and the addition to tax for income not earned in a province by an individual under Section 120 of the same Act. 24. ...

The second issue is whether the appellant was entitled to claim in 1986, 1987, 1988 and 1989 extended capital gains reserves pursuant to paragraphs 40(1)(a) and 40(1.1)(c) of the Act in connection with the transfer in 1986 of 100,000 shares of Ronlar to his son Darryl Paxton ("Darryl"). ... In the event that the transaction does not close by reason of the non-fulfilment of one or more of the conditions contained in clause 9.1(1), clause 9.1(2) or clause 9.1(3), then the deposit and all interest thereon shall be non-refundable and may be retained by the vendors in full satisfaction of their costs incurred in connection with this agreement of purchase and sale. 3.3 Each of the vendors shall have the right exerciseable by written notice to the purchaser at any time prior to two business days before the closing date to elect to make an interim transfer of all or part of the purchased common shares to other family members of the vendors (the "subsequent vendors") provided that such transfers are only valid if the subsequent vendors complete the sale and transfer of the purchased common shares to the purchaser in accordance with the terms of this agreement. Each of the vendors undertakes that in the event of any such election the vendors shall take all such steps as are necessary to cause and require the subsequent vendors to complete all the transactions contemplated by this agreement and each of the vendors warrants to the purchaser that all such transactions will be so completed. 4,1 Each of the vendors jointly and severally covenants, represents and warrants as follows and acknowledges that the purchaser is relying upon such covenants, representations and warranties in connection with the purchase herein: (5) all of the purchased common shares are now owned by the vendors and will be owned at the closing date by the vendors or the subsequent vendors as the beneficial owners of record, with good and marketable title thereto, free and clear of all mortgages, liens, charges, security interests, adverse claims, pledges, encumbrances and demands whatsoever; (7) no person, firm or corporation has or will have at the closing date any agreement or option or any right or privilege (whether by law, preemptive or contractual) capable of becoming an agreement or option for the purchase from the vendors or the subsequent vendors of any of the purchased common shares or any of the special shares (except the purchaser pursuant to the put agreement), or the purchase from Ronlar of any shares in the capital of the corporation; 5.1 Each of the vendors jointly and severally covenants and agrees with the purchaser that on or before the closing date (or after the closing date with respect to the covenants in clause 5.1(16) and clause 5.1(17)) he will do or will cause to be done the following: (5) the vendors will take all necessary steps and proceedings as approved by counsel for the purchaser to permit all of the purchased common shares to be duly and regularly transferred to the purchaser or its nominee(s); 8.2 If any of the foregoing conditions shall not be fulfilled and/or performed by the vendors at or before the closing date to the satisfaction of the purchaser, the purchaser may rescind this agreement by notice to the vendors and in such event the purchaser shall be released from all obligations hereunder and unless the purchaser can show that the condition or conditions for the non- performance of which the purchaser has rescinded such agreement are reasonably capable of being performed or caused to be performed by the vendors or either of them, then the vendors shall also be released from all obligations hereunder; provided that any of the said conditions may be waived in whole or in part by the purchaser without prejudice to its rights of rescission in the event of the non-fulfilment of any other condition or conditions, any such waiver to be binding on the purchaser only if the same is in writing. 9.2 If any of the foregoing conditions shall not be fulfilled and/or performed by the purchaser at or before the closing date to the satisfaction of the vendors, the vendors may rescind this agreement by notice to the purchaser and in such event the vendors shall be released from all obligations hereunder and unless the vendors can show that the condition or conditions for the non- performance of which the vendors have rescinded such agreement are reasonably capable of being performed or caused to be performed by the purchaser, then the purchaser shall also be released from all obligations hereunder; provided that any of the said conditions may be waived in whole or in part by the vendors without prejudice to their rights of rescission in the event of the non-fulfilment of any other condition or conditions, any such waiver to be binding on the vendors only if the same is in writing signed by both of them. 11.1 Each of the vendors jointly and severally covenants and agrees to indemnify and save harmless the purchaser, the corporation and Ronlar (subject to the limitations as to time set forth in Article 7) of and from any loss whatsoever arising out of, under or pursuant to: Counsel for the respondent refers to Article 3.1 and points to the fact that it is the appellant and his co-vendor who have the discretion to direct to whom the payment cheques for the shares are to be directed, 1.e., to "whomsoever they may direct". ...

In this connection he mentioned in particular the Métro name, the prestige connected with this banner and the advertising done by Métro. ... Brunetta noted that Métro secured two important benefits: a long-term connection with a food merchant and a better concentration of purchasing of its products. ... That penalty and the ratios required however have no connection with the volume discount or other discounts currently in use.-— Right of first refusal over the sale of the business or shares of the company, right to a possible lease of the premises of the food market. ...

There has been a difference of opinion on whether the word “combination” in subsection 13(1) requires some “connection” by way of physical relationship or integration or inter-connection between farming and the subordinate activity which provides another source of income. Paragraph 3(f) of the Income War Tax Act of 1917, as amended, made reference to "connection" in the finding of permissible deductions from income derived from the chief business, trade, profession or occupation of the taxpayer, in determining his taxable income. ...

In accepting the above arrangements, you agree with PanCanadian that during the time this arrangement is in effect, and for a period of two years following termination of our arrangement, you will keep confidential, all information which you have pertaining to the business of PanCanadian resulting from your activities in connection with its operations. ... He had severed his connection with PanCanadian within a few months of agreeing to the contract dated 1979-09-28 above. ... It would be a relatively simple task in my view to go down all the expenses claimed during the years in question, and eliminate or seriously question the need for them — in connection with the earning of the income. ...

However, the appellant admitted that among the documents received in connection with the adoption of this first child was a detailed statement of the costs incurred by Cathwel for the mother and the child; this document was entitled “Expenditures”. [2] Listed in the document were the costs for prenatal care, for the delivery and for postnatal care. ... The appellant testified that, in connection with this adoption, he did not receive a document from Cathwel itemizing expenses as had been the case in 1991 when the first child was adopted. ... Brunelle explained it as follows: [TRANSLATION] The letters were addressed to the Jesuits because that was the connection we had between Quebec and Sister Rosa, it was the route that we knew, because, among other things, when my sister-in-law, who is my daughter’s godmother and who went to get her over there, she went to the Jesuits because she had a friend in common which Father Aubin, and she went to mass over there with Sister Rosa; also the building in which Cathwel is located belongs to the Jesuits. ...

‘Tangibles’5 [5] means all of the Vendor’s right, title, estate and interest in and to all tangible depreciable property and assets (except casing) situate in, on or about the Lands, appurtenant thereto or used in connection therewith and with production operations thereon including, but not in limitation of the generality of the foregoing, appurtenant to or used in connection with all producing or shut-in wells located on the Lands. 15 January 1986 (D) Lone Rock and all of its shareholders enter into a share purchase agreement with the appellant whereby the latter acquired all of the shares of Lone Rock. ... Subparagraph 66(15)(c)(iii) reads: (iii) any oil or gas well in Canada or any real property in Canada the principal value of which depends upon its petroleum or natural gas content (but not including any depreciable property used or to be used in connection with the extraction or removal of petroleum or natural gas therefrom). 29 September 1986 (E) Lone Rock as transferor and the appellant as transferee enter into a “Distribution Agreement” whereby Lone Rock “assigns, transfers and conveys to and sets over unto the transferee all of the right, title and interest of the transferor in and to all its property, assets and business”. ...

.; (1) Pied-Mont Dora Inc. is the owner of the trademarks used in connection with the above-mentioned flavour crystals; (j) Net income generated by the appellant’s crystals business was $185,184, $147,249 and $121,102 for taxation years 1991, 1992 and 1993 respectively; (k) Net losses incurred in the racehorse business and claimed by the appellant were $160,750, $70,522 and $193,229 for taxation years 1991, 1992 and 1993 respectively; (1) The appellant deducted the losses suffered in the racehorse business from the income generated by the sale of crystals; (m) The operation of the appellant’s racehorse business from July 1, 1989 to December 31, 1993 never generated any profits; rather it generated operating losses of about $651,195: (n) In the years at issue, the appellant’s chief source of income was neither a farming activity nor a combination of farming and some other source. ... I quote from pages 486 to 489: There has been difference of opinion on whether the word “combination” in s. 13(1) requires some “connection” by way of physical relationship or integration or inter-connection between farming and the subordinate activity which provides another source of income.... ...

Issue [6] The issue is whether, for the purposes of qualifying for the ITC claimed, the appellant met the applicable conditions of paragraph 169(4)(a) of the ETA and the Input Tax Credit Information (GST/HST) Regulations, SOR/91-45 (the Regulations) in connection with the Lessor’s GST number. ... The witness confirmed that the Lessor’s GST number was obtained after he had asked the Lessor to provide it and that this number was in his possession before any income tax returns containing an ITC claim in connection with the Lessor were prepared. [20] With respect to the failure to send the Lessor’s GST number to the Agency in the context of the objection submitted against the 2015 income tax return, he could not recall that the agent had expressly requested the Lessor’s GST number to provide a rationale for entitlement to the ITC. [21] The witness explained that when a fax in support of the objection was sent on March 25, 2019, he attached an extract from the Registraire des entreprises relating to the Lessor proving the existence of a corporate name, Gestion 170 René-Lévesque, used by the Lessor. ... Therefore, if taxpayers are to act with any degree of certainty under such a regime, then full effect should be given to Parliament’s precise and unequivocal words. [49] The clarifications made above by the Canada Revenue Agency are supported by the wording of paragraph 169(4)(a) of the ETA and are consistent with the meaning and scope to be given to the measures described in the Regulations concerning the particulars that a registrant must obtain in connection with a supply. [50] More specifically, it does not seem appropriate that the general wording of the preamble to the definition of supporting document in the Regulations should be given a scope limited to the list that follows the preamble. ...

He claimed the MacLaren Art Centre was very important to him because he had connections to the person responsible for establishing it, the Gallery was in his hometown, and he had a lifetime appreciation for art. [9] While not much turns on this, I find the Appellant’s claimed interest in assisting the MacLaren Art Centre dubious, and most likely constructed at the time of trial. ... The Amended Loan Application contained revised provisions of the Original Loan Application to, inter alia, remove the loan’s connection to the Ideas donation, which Mr. ... Particularly in 2002, these changes did not eliminate all the references to the connections between Ideas and the loan from Talisker; (iv) The Appellant’s participation was different than other donors. ...