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Hay was made aware by Equifax Canada Inc. early in 1999 that the Ministère had enquired about his creditworthiness in connection with "its effort to apply fiscal laws". ...

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. ...

Additionally, I would note that there is no evidence in this connection to show that the recipient parent or the children would benefit by taxation in the hands of the payer of the alimony, as the ordinary rules of taxation under the general system would postulate. ...

He described his duties as primarily in connection with the purchase of toys for the Christmas customers, though likewise acknowledged he handled shipping and receiving, packing, janitorial, customer relations, delivery and even banking on occasion. ...

Owl & Associates Ezra Owl Belmont Auto 1262672 Ontario Ltd. n/a Waytee Inc. n/a 1283915 Ontario Ltd. n/a Bravo Management Services Inc. n/a Peleshok Motors (Ajax) Ltd. n/a Technessen Ltd. n/a The American German Connection Inc. n/a l)           Ken Parker did not deal at arm's length with 1070699 Ontario Ltd. and 1081528 Ontario Ltd.; m)         all of the purchasers had previous dealings with Ken Parker and were willing to accommodate him in the transactions and purported transactions to facilitate the execution of the scheme described above; n)          the motor vehicles referred to in subparagraphs 8(e) and (g) were never delivered to or made available to the Appellant and they were never under the Appellant's authority or control; o)          the Appellant never negotiated the sale or purchase of any of the vehicles referred to in subparagraphs 8(e) and (g) but simply acted as a conduit for the transfer of funds and allowed invoices to be produced in its name; p)          neither the Appellant nor any agent of the Appellant had possession of, legal title to or interest in any of the motor vehicles referred to in subparagraphs 8(e) and (g) during the period under appeal; q)          in filing its' GST/HST returns for the period under appeal, the Appellant reported the 7% HST collected with respect to the transactions referred to in subparagraphs 8(e) and (g) and claimed the 15% HST the Appellant paid with respect to those same transactions as ITCs; r)           none of the vendors have filed GST returns; s)          some of the motor vehicles referred to in subparagraphs 8(e) and (g) were owned by third parties at the time of the alleged purchases and sales by the Appellant and neither the Appellant nor the vendors had legal title to or an interest of any kind in those motor vehicles; t)           some of the motor vehicles referred to in subparagraphs 8(e) and (f) did not exist at the time of the alleged purchases and sales by the Appellant; u)          some of the motor vehicles referred to in subparagraphs 8(e) and (f) never changed hands from the person who owned them at the time of the alleged purchases and sales by the Appellant; v)          in its tax return for the month of September, 1998 the Appellant reported tax collected of $82,358 and claimed ITCs of $176,979; w)         of the ITCs claimed in September, 1998 $168,075 related to purported transactions as described above; x)          the Appellant had no documentation or books and records of any kind to support its claim for ITCs in September, 1998 although a total of $1,288,575 was paid to one of the vendors in that month; y)          the transactions referred to in subparagraphs 8(e) and (g) were not bona fide business transactions; z)          the Appellant claimed ITCs in relation to the following vehicles twice: Vehicle VIN First Claim Second Claim ITC Claimed 018111 Oct. 1997 Nov. 1997 $6,505.65 WE147418 Nov. 1997 Jan. 1998 $5,753.10 W0181700 July 1998 July 1998 $6,000.00 aa)        the scheme described above, particularly in subparagraph 8(j), was an artificial arrangement executed by the Appellant and the vendors to give the appearance that the Appellant was purchasing and selling the automobiles described in subparagraphs 8(e) and (g) when such was not the case; and bb)        the invoices created by John Bruce at the vendors' instructions were created solely for the purpose of effecting the aforementioned artificial arrangement and did not reflect actual purchases and sales; ANALYSIS AND CONCLUSIONS: [18]     I found E to be entirely credible. ...

This is particularly true when the person has no prior employment connection with the party who benefits from his services. ...

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

Most of the amounts invested by Management were first advanced to Salvage, which then paid its suppliers. [12]          During his testimony, Michel Bernier, a tax specialist with RCMP, pointed out on a document (Exhibit A-5) the following additional expenses that Management wishes to deduct as its own expenses: [TRANSLATION]                                                                                                     $                          Balance as at April 30, 1993                                                                 22,201.12 [6] Cheque transfer to [MTI] And/or Michel Tadros in connection with the project                                 B              882                           4,999.00                                 B              902                           5,000.05                                 B              941                           300.00                                                                                                                 10,299.05 Transfer to Denis Boissonneault [sic] 07-10-93 B              976                                                           400.00 Invoices paid by [Management] 20-05-93 Centre Plongée Gaspé Inc.                  800.00 05-06-93 Boutique du Plongeur Ltée                                 3,215.00 [7]                                                                                                                 36,915.17 [13]          According to Mr. ...

In connection with this determination, Drummond gave an undertaking dated March 27, 1981 to the Superintendent of Brokers whereby Drummond agreed that it would not dispose of CNR shares without first applying for a ruling under section 55, or qualifying the CNR shares by way of a prospectus or statement of material facts. 11. ...

This is particularly true when the person has no prior employment connection with the party who benefits from his services. ...