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In addition, the fact that a person segregates from its own funds any monies received or paid in connection with another person is indicative of an agency relationship. … … Remuneration Remuneration of an agent generally takes the form of a set fee. ...

While further proof was provided of his depression, there was no evidence demonstrating the causal connexion of his mental distress with the decisions to make the contributions or, albeit though his financial advisor, the delay in taking steps to eliminate the excess contributions. [74]            The Applicant did not seriously challenge the Decision to apply the interest and penalty provisions pursuant to subsection 220(3.1). ...

Factual Background [8]                In the course of an audit for the 2000 and 2001 taxation years, the CRA informed Sentinel Hill MLP that it had concerns regarding certain deductions claimed in connection with expenses on grounds that they were unreasonable. [9]                The statutory provision empowering the Minister to disallow deductions for unreasonable expenses is section 67 of the Income Tax Act, R.S.C., 1985, c. 1 (5 th Supp.) ...

When asked in cross-examination if one of the reasons he gave the Amount to Global was because of a connection to pranic healing, he said he was unable to recall if it was involved in that and did not know whether or not in 2001 Global’s primary purpose was to carry on support programs in British Columbia. [60]   R esponding to questions put to him as to whether he knew how the Amount would be invested by Global, he said he understood it was to be placed into an endowment fund, it would generate interest but did not know where or how the endowment fund was going to earn income and acknowledged he had never donated a nything to an endowment fund. ...

Murray also explained that:- taxpayers can obtain information with respect to the audit of returns upon the issuance of a reassessment; and- some audit methods and techniques appearing in the CTR have no connection to the issue raised in the application. ...

ITCs and Commercial Activity [40]   The statutory provision that permits the claiming of an ITC is subsection 169(1) of the ETA, the relevant portion of which states: 169(1)   Subject to this Part, where a person acquires … property or a service … and, during a reporting period of the person during which the person is a registrant, tax in respect of the supply … becomes payable by the person or is paid by the person without having become payable, the amount determined by the following formula is an input tax credit of the person in respect of the property or service for the period: A Ч B where A   is the tax in respect of the supply … that becomes payable by the person during the reporting period or that is paid by the person during the period without having become payable; and B   is (a)   …, (b)   where the property or service is acquired … by the person for use in improving capital property of the person, the extent (expressed as a percentage) to which the person was using the capital property in the course of commercial activities of the person immediately after the capital property or a portion thereof was last acquired … by the person, and (c)   in any other case, the extent (expressed as a percentage) to which the person acquired … the property or service … for consumption, use or supply in the course of commercial activities of the person. [41]   For the purposes of these Appeals, subsection 169(1) of the ETA sets out three conditions that must be satisfied by a person to be eligible to claim an ITC, as follows: a) the claimant must have acquired property or a service; b) GST must have been payable or paid by the claimant in respect of the supply; and c) the claimant must have acquired the property or service for use in improving capital property used in its commercial activities or for consumption, use or supply in the course of its commercial activities. [44] [42]   The term “commercial activity” is defined in subsection 123(1) of the ETA, as follows: “commercial activity” of a person means (a) a business carried on by the person …, except to the extent to which the business involves the making of exempt supplies by the person, (b) an adventure or concern of the person in the nature of trade …, except to the extent to which the adventure or concern involves the making of exempt supplies by the person, and (c) the making of a supply (other than an exempt supply) by the person of real property of the person, including anything done by the person in the course of or in connection with the making of the supply…. ...

His counsel also cited Charter jurisprudence in his submissions to the CAO in connection with Dr.  ...

It has listed Canadian Patent No. 1,341,537 (the ‘537 Patent) in connection with these products on the Patent Register. ...

"impartial: the interpreter should have no connection to parties or interest in the outcome. ...

TNS operates as the connection point to the payment networks for ATMs whereby ATMs connect to the TNS network. ...