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The phrase has had some judicial consideration in connection with the presumption in equity against double portions. ... It was stated in In Re Lawes (1881), 20 Ch.D. 81 at p. 86, again in connection with the presumption against double portions, that a father stood in loco parentis with respect to his illegitimate child. ...

The appellant complains that the respondent has improperly applied subparagraph 22(1)(l) of The Corporations Tax Act, SO 1972 c 143 as amended by SO 1973 c 42, the relevant portions of which, as so amended read as follows in the taxation years in question: (1) In computing the income of a corporation from a business or property no deduction shall be made in respect of, (I) five-twelfths of the aggregate of amounts each of which is an amount in respect of (iii) a right in or to use of motion picture films or films or videotapes for use in connection with television that have been or are to be used or reproduced by the corporation in Canada, that were paid or credited, or deemed to be paid or credited, in the fiscal year to a non-resident person with whom the corporation was not dealing at arm’s length, On behalf of the appellant it is submitted that this section can only apply where the taxable corporation itself uses the film or videotape by broadcasting and that this interpretation is necessary because the words “used or reproduced” are followed immediately by the words “by the corporation”. ...

The services referred to include those of articling students and title searchers in connection with searching the title to the property, consideration given by lawyers to the zoning by-laws, a site control agreement, a site plan agreement and a lease, consideration given to income tax aspects, and work done in negotiating the transaction and settling the documents with the solicitors for other interested parties. ... Apart from certain minor errors in the description of number 18 and number 36 which were the subject of discussion in court and were found to be not of any material significance, the documents are accurately described in the schedule to the agreed statement of fact and I go on to say that they clearly contain legal advice or refer to the giving of legal advice in connection with this project. ...

In this connection I have been referred to Sections 13 to 15 of the Interest Act, R.S.C. 1952, c. 156, but I think that those sections are, by reason of Section 12 of that Act, quite inapplicable to any of the matters before me on this reference. ... In this connection I have considered the following cases cited: (a) by the solicitor for Her Majesty—Commissioners of Taxation for the State of New South Wales v. ...

An appeal having been launched, any procedure in connection with that appeal must be something authorized by the Rules of the Tax Appeal Board and no such rule authorizes the employment of the machinery set up by Section 126(4). ...

The only limitation is that if the question of relationship happens to arise in connection with the interpretation of a will or instrument, then Section 10 does not apply if the testator died before April 17, 1920, or to an instrument made before that date. ... Riddell, J.A., said this in connection with the question whether a man killed in an accident stood in loco parentis to his sister, on pp. 549-50: Our own Courts do not give much assistance in the enquiry. ... The offices and duties of a parent are infinitely various, some having no connection whatever with making a provision for a child; and it would be most illogical, from the mere exercise of any of such offices or duties by one not the father, to infer an intention in such person to assume also the duty of providing for the child.” ...

During the Second World War it was found necessary to encourage and stimulate the production of oil in Canada; accordingly, by P.C. 3567 of May 4, 1943, authority was given under the War Measures Act for the incorporation of a Crown corporation—Wartime Oils Limited—charged with the duty of negotiating and entering into contracts for the carrying out of said objective and for the furnishing of financial assistance in connection therewith. ... As the companion well of Well No. 18 was productive, Wartime Oils might at some date acquire a 14 of 1 per cent royalty in perpetuity therein, but in the result it never could acquire any royalty in connection with Well No. 20 or its companion Well No. 22. ...

The essential part of the requirement for production served pursuant to subsection 231(3) of the Act provides as follows: For purposes related to the administration or enforcement of the Income Tax Act, pursuant to the provisions of Subsection 231(3) thereof, I hereby require from you the production of all file indices, letters, notes, correspondence, books, accounts, invoices, statements (financial or otherwise), agreements, documents, evidencing deeds, and any other material in your possession or under your control, having either a direct or indirect bearing on: (a) the incorporation of Playfair Developments Limited (hereinafter called Playfair) (b) the share structure, share ownership, capitalization and financing of Playfair since inception (c) the lending of funds to Playfair on March 13, 1976 by Parfindus Etablissement (Parfindus) and Chanex Etablissement (Chanex), two companies incorporated under the laws of the Principality of Liechtenstein (d) the issuance on March 31, 1976 of 46,000 Class “A” preferred shares, ie 23,000 to Parfindus and 23,000 to Chanex (e) the transfer of the funds referred to in (c) from the Liechtenstein companies to Playfair (f) negotiations between Brian B Freeman and the Canadian Imperial Bank of Commerce to obtain financing or loans either for himself or for Playfair (g) the assets and liabilities of Playfair but without restricting the generality of the foregoing, specifically the purchase from Cutaia Investments Limited by Brian B Freeman and Bohdan S Onyschuk as Trustees for Playfair of the property located at 25 Main St West in Hamilton, Ontario, known as the IBM Building (h) the transfer of funds by Playfair to or on behalf of Parfindus and/or Chanex in the years 1976 through 1981 (i) any business connection, relationship, or employment or agency agreement involving Playfair and/or Brian B Freeman on the one hand and Robert E Mann and/or R E Mann Agencies Limited on the other (j) any arrangement, agreement, compact or undertaking of any kind whatsoever, related to any of the matters listed above, between any person or company named above, and any or all of the following persons:— Bohdan S Onyschuk Umberto Casalegno Ercole Doninelli Antonio Escher Franco Pettazzi Ottavio (Tito) Riccadonna Saverio Schiralli Saverio Schiralli Agencies Limited Largo Solindi It is clear from the material before me that the real issue relates to the documents relating to the involvement of the named persons in the purchase of a property in Hamilton known as the IBM Building from Cutaia Investments Limited. ... In my approach to the problems raised by various documents I will attempt to resolve at least some of them, by deciding whether the communications were in connection with what could be broadly described as solicitors’ work for the clients, or in connection with business operations of the corporation. ...

Mr Davis expressed his previous point of view in the case of G Rosenberg v MNR, [1968] Tax ABC 1131; 68 DTC 830 when he said at 834: Mr Goodman further argued that, notwithstanding the fact that the appellant had objected only to the disallowance of the deduction of his personal loans to the company as a bad debt (which he then referred to as amounting to $3,500 but which he has established in his evidence as amounting to $3,550), he was nevertheless entitled to include in his notice of appeal to this Board a claim in connection with the additional amount of $2,450 which he was obliged to pay to the bank on his guarantee. ... I therefore hold that this Board is without jurisdiction to deal with the amount of $2,450 which the appellant was obliged to pay to the bank in connection with his guarantee of the company loan and overdraft. ... In this connection, counsel for the respondent made a curious statement in the course of argument, namely that the appellant, and I suppose all other mining companies in a similar position “should have anticipated that the Provincial law would follow the Federal”. ...

The applicants were cleared of any wrongdoing in that connection. The charges do not relate to the failure to remit. ... Paragraphs 231(l)(a) and (d) provide as follows: 231. (1) Any person thereunto authorized by the Minister, for any purpose related to the administration or enforcement of this Act, may, at all reasonable times, enter into any premises or place where any business is carried on or any property is kept or anything is done in connection with any business or any books or records are or should be kept, and (a) audit or examine the books and records and any account, voucher, letter, telegram or other document which relates or may relate to the information that is or should be in the books or records or the amount of tax payable under this Act. ...