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During that period, he maintained his own bank account and played a small role in connection with the operation of the Nguyen household. ...

That definition then read: 237.1 (1)           In this section, "tax shelter" means any property in respect of which it may reasonably be considered having regard to statements or representations made or proposed to be made in connection with the property that, if a person were to acquire an interest in the property, at the end of any particular taxation year ending within 4 years after the day on which the interest is acquired, (a)        the total of all amounts each of which is (i)         a loss represented to be deductible in computing income in respect of the interest in the property and expected to be incurred by or allocated to the person for the particular year or any preceding taxation year, or (ii)        any other amount represented to be deductible in computing income or taxable income in respect of the interest in the property, and expected to be incurred by or allocated to the person for the particular year or any preceding taxation year, other than any amount included in computing a loss described in subparagraph I, would exceed (b)        the amount, if any, by which (i)         the cost to the person of the interest in the property at the end of the particular year, would exceed (ii)                 the total of all amounts each of which is the amount of any prescribed benefit that is expected to be received or enjoyed, directly or indirectly, in respect of the interest in the property, by the person or another person with whom the person does not deal at arm's length. [7]   Ms. ...

Moreover, the only evidence filed during the hearing that showed he was paid for his professional services had to do with an amount of $683 he received on February 9, 1999, for services provided to the Brotherhood in connection with the Railway Medical Rules Review (Exhibit A‑1, Tab 4). ...

The Minister delayed confirmation of the assessments in an attempt to resolve the thousands of objections filed in connection with the SRED tax shelters. ...

Lastly, it will be noted incidentally that employee status can coexist, in the same person and in connection with the same economic or professional activity, with another status such as shareholder or director of the company, independent contractor or even employer. ...

CRA's original letter, dated October 30, 2006, from its Toronto East Tax Services requested documents and records in connection with an audit by the CRA of Global Learning Gifting Initiative ("Global Learning") for the 2004 taxation year. ...

In that connection, she checks their references; otherwise, she said, she does not care ...

On November 22, 2006, the CRA replied that the seven workers in question [TRANSLATION] "were not part of the appeal filed on January 23, 2006, and were therefore not part of the Notice of Appeal that had been accepted in connection with the assessment of February 10, 2006 (sic), which covered the 2002, 2003 and 2004 years". ...

  [22]     Before turning to the Appellant’s alternative arguments, I note that the Appellant argued that the amendment to the Act effective in 1997 helps make its point that a contractual connection between the supplier and the person to whom the property was supplied was not required under the provision as it read prior to that amendment. ...

Overall, on a close scrutiny and assessment of this evidence I find it difficult to conclude that Beavies did use this vehicle in connection with the commission of a designated substance offence. ...