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By the first Supplementary Letters Patent, the original purposes and objects were expunged and replaced by the following objects: (a) to purchase or otherwise acquire for investment, and to hold for investment, property, real and personal, of every kind and nature, and any estate or interest therein, and to manage and supervise such investment; (b) to buy, sell, manufacture, assemble, install, import, export and otherwise deal in fans, blowers, furnaces, refrigerators, ventilating, air conditioning, cooling and heating equipment for commercial, industrial or domestic use and all kinds of filters, electronic or electrical or other power equipment, motors or devices connected or used in connection therewith. ... Since the lease was a net net net lease, basically all costs in connection with the property, eg flower bed, landscaping, grass cutting, snow removal, painting and major roof repair jobs, were paid for by Greensteel but the supervision of that work was done by Transregent, which supervision was usually by three of the directors of Transregent including Mr Martin. ...

They read as follows: 212.(5) Every non-resident person shall pay an income tax of 25% on every amount that a person resident in Canada pays or credits, or is deemed by Part I to pay or credit, to him as, on account or in lieu of payment of, or in satisfaction of, payment for a right in or to the use of (a) a motion picture film, or (b) a film or video tape for use in connection with television that has been or is to be used or reproduced in Canada. 227.(7) Where, upon application by or on behalf of a person to the Minister pursuant to subsection (6) in respect of an amount paid to the Receiver General of Canada that was deducted or withheld under Part XIII, the Minister is not satisfied (a) that the person was not liable to pay any tax under that Part, or (b) that the amount paid to the Receiver General of Canada was in excess of the tax that the person was liable to pay the Minister shall assess that person for any amount payable to him under Part XIII and send a notice of assessment to that person, whereupon Divisions I and J of Part I are applicable mutatis mutandis. 5.2 Cases The parties referred to the following cases: A. ... For a better understanding of the meaning of subsection 212(5) it would be useful to compare the two official texts, in English and French: Subsection 212(5)—English 212.(5) Every non-resident person shall pay an income tax of 25% on every amount that a person resident in Canada pays or credits, or is deemed by Part I to pay or credit, to him as, on account or in lieu of payment of, or in satisfaction of, payment for a right in or to the use of (a) a motion picture film, or (b) a film or video tape for use in connection with television that has been or is to be used or reproduced in Canada. ...

Other personal cheques in connection with expenses of the preparatory work in the production of “The Strange One” were produced as Exhibit A-9 and one in connection with the film rights of another novel called “Settlers of the Marsh” for an amount of $1,000. ...

Pursuant to the agreement, the taxpayers agreed at their expense to provide connections to the municipal water supply, to install a septic tank, to provide plumbing for at least one toilet, hot and cold running water, a bathroom and kitchen sink and a hot water tank and bathtub. ... For his own future use, he also installed washer connection piping although at the time of the installation a washer was not required by the sisters. ...

Was there a mutual connection and justification between the existence of the company, its purpose and the services rendered? ... The company appears to have been only a tool used to artificially reduce the appellant’s income. 4.3.9 Was there a mutual connection and justification between the existence of the company, its purpose and the services rendered? ...

Obligations assumed in connection with and for the purpose only of betterment of property owned by a man do not necessarily constitute him a person who carries on business. ... These are refinements offered to the tenants in connection with the occupation of suites and, in most instances, are also property for the use of which, along with the suites themselves, rent is paid. ...

Mr Weintraub maintained an office in his home and his wife looked after the books and answered the telephone in connection with advertisements for employees or for rental of office space.... ... He would also receive telephone calls at home in connection with the company’s business. ...

However, it was ascertained that the amount stated in that invoice was less than the amount stated in the invoice which Mitsui Japan issued in connection with the same vehicle. ... As indicated by Exhibit R-1, in August Mr Torrance wrote a 4-page letter to the Deputy Minister of Customs and Excise in connection with the matter, and in that letter indicated that, while his clients wished to negotiate a settlement, the real point ‘‘at issue is the penalties claimed amounting to $328,065.94”. ...

I do not believe that the degree or the extent of the taxpayer’s activity in connection with the normal operation and maintenance of a long-term rental property can automatically transform the taxpayer’s investment in such property into an investment in a business. ... In this connection there is some evidence that in 1972 a new furnace was installed at a cost of approximately $525, but there is no indication of other “major repairs’’. ...

Dr Anderegg did say that the Otto Versand did own property, did buy property, and did sell property, but solely in connection with its catalogue business. ... Mr Larsen also admitted that Exhibit R5 was the account the appellant received from its Ontario solicitor, Mr Strauss, and the attention of the Board was directed to the words in the account which I have italicized: Re: York-Adelaide Lot Sale to The Prudential Assurance Company Limited TO PROFESSIONAL SERVICES rendered in connection with the sale of the above captioned property to The Prudential Assurance Company Limited including the negotiating of the Option to Purchase and several revisions thereof, lengthy discussions concerning area of subject lands, meetings with surveyors, negotiations with solicitors for Purchaser, preparation of closing documentation including revisions thereof and satisfying corporate requirements, and to satisfactorily completing the transaction, attending at closing and reporting thereon. ...