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Its business was the conduct of research, particularly in connection with construction. ... Shead"s connections with Anaquan and Mr. McLellan, Anaquan"s first president, go back to 1984 when he incorporated the company and subsequently acted as an adviser to it. ... Shead"s long standing connection with Anaquan and Mr. McLellan. Indeed, Mr. ...

In part because the statute does not specify that members of the CITT need have any particular technical qualifications, Mattel Canada argues that the appropriate standard of review of the CITT’s decision in the present appeal should be reasonableness.   30           In this connection, Wilson J. observed in National Corn Growers Assn. v. ... Minister of National Revenue (Customs and Excise) (1997), 131 F.T.R. 102, MacKay J. concluded that royalties may be a condition of sale as long as there is “some connection between the fee in question and the goods purchased” (p. 108).  ... The Deputy Minister used similar language like “true connection”, “effective control”, “practical” and “logical” to describe the manner in which the royalties that Mattel Canada paid to Licensor X could constitute “a condition of the sale of the goods for export to Canada” as between Mattel U.S. and Mattel Canada.   64           The words “condition of the sale” as they appear in s. 48(5)   (a)(iv) are clear and unambiguous.  ...

Stewards are persons who have a commercial connection with the designated waste or with a product from which the designated waste is derived.- The stewards are required to pay fees to the industry funding organization. ... Once a person is found to have, under the MHS Waste Program Agreement, the required commercial connection with the MHS Waste, the person is deemed to be an MHSW Steward. ... So there’s a connection between the volumes they produce, generate and sell, and what they pay. [38] [115]   In short, the fee is an estimate of the costs the Appellant incurred in collecting and recycling the MHS Waste with which the steward has a commercial connection under the WD Act. ...

In particular, Lazard Frères, being a French firm, had the necessary connections and experience to assist with issues arising in France and with the analysis of French capital markets: see Reasons at paras. 12 and 21. [10]   On July 2, 2003, the Alcan board of directors approved a purchase offer proposal for Pechiney’s share capital. ... It noted that no one who provided services in connection with the financial information was called to testify. ... Alcan argued, on the basis of paragraphs 34 to 38 of ITA Travel, that “commission” meant an amount calculated by reference to a percentage of the price of a product or a percentage of the profit earned by a principal in connection with a transaction. ...

Robinson had mentioned his age as being a factor there was no connection found between his age and his ability to pay his taxes. ... The Decision Maker indicated he had reviewed the cases and found no connection between the facts of those cases and Mr.  ... He claims that the non-filer NOA was the cause of the penalty and interest charged to him and it was an error on the part of CRA to issue it. (1)   The Alleged Causal Connections [91]   When asked at the hearing to explain to the Court the causal connection between the issuance of the non-filer NOA and the claim that Mr.  ...

The Third Party Respondents Distributel Communications Limited [Distributel] and Cogeco Connexion Inc. ... In doing so the user will only rely on the ISP to facilitate the connection to the VPN; all other Internet connections are initiated through the VPN thereby avoiding any blocking undertaken by the ISP. ... DBA EASTLINK COGECO CONNEXION INC. DISTRIBUTEL COMMUNICATIONS LIMITED FIDO SOLUTIONS INC. ...

It used to claim refundable ITCs in connection with its SR&ED activities, but ceased doing so when it became public in 2004. [10]   In 2005, Public CO2 had the following structure. ... It had its own bank account, its accounting, its financial statements, and so on and so forth. [24]   If there was any connection between the appellant and Public CO2, it was that of a partnership stemming from the research contract and from the fact that it retained intellectual property. ... In connection with these expenses and under subsections 127(9), 127(10.1) and 127.1(1) of the ITA, the appellant claimed an investment tax credit (hereafter “ITC”) of $291,055 and a refundable ITC of $280,112. ...

It should be noted that the Minister does not represent France and has no connection to this matter other than as the Canadian competent authority for obtaining the information and documents required by France under the Convention. [74]   France clearly has a genuine and valid interest in opposing Blue Bridge’s applications because the declaratory order sought would contravene a decision of a French court having jurisdiction in the matter. [75]   It is not for Blue Bridge to judge the appropriateness of France’s legislative choices in the arena of taxation or to deprive its tax authorities of the information it could use to perform its auditing functions. ... The requests made by France show the connections between the French residents and the Trusts at issue in this judgment. The Minister has no obligation whatsoever to verify the information supplied by France. [114]   Having studied the requests from the French authorities in connection with the French residents under investigation, the Minister assessed the foreseeable relevance of the required information, pursuant to Article 26(1) of the Convention. ...

In this connection I also note the Federal Court of Appeal’s recent decision holding judicial review of procedural fairness issues is conducted on the correctness standard: see Canadian Association of Refugee Lawyers v. ... I find nothing unreasonable in the identification and weighing of the evidence by the Minister’s Delegate in this connection; it comports with constraining jurisprudence and was open on the record. [56] Second, the Applicant submits the Minister’s Delegate erred in their assessment of her medical condition. ... There should be and are guidelines to be factored into decisions in this connection. ...

Beyond that, the sections of the legislation are as follows: Taxes in Respect of Registered Plans 207.01 advantage, in relation to a registered plan, means (the “TFSA Advantage”) (a) any benefit, loan or indebtedness that is conditional in any way on the existence of the registered plan, other than [enumerated exceptions in (i)-(v)]; (b) a benefit that is an increase in the total fair market value of the property held in connection with the registered plan if it is reasonable to consider, having regard to all the circumstances, that the increase is attributable, directly or indirectly, to (i) a transaction or event or a series of transactions or events that (A) would not have occurred in a normal commercial or investment context in which parties deal with each other at arm’s length and act prudently, knowledgeably and willingly, and (B) had as one of its main purposes to enable a person or a partnership to benefit from the exemption from tax under Part I of any amount in respect of the registered plan, (ii) a payment received as, on account or in lieu of, or in satisfaction of, a payment (A) for services provided by a person who is, or who does not deal at arm’s length with, the controlling individual of the registered plan, or (B) of interest, of a dividend, of rent, of a royalty or of any other return on investment, or of proceeds of disposition, in respect of property (other than property held in connection with the registered plan) held by a person who is, or who does not deal at arm’s length with, the controlling individual of the registered plan, (iii) a swap transaction, or (iv) specified non-qualified investment income that has not been paid from the registered plan to its controlling individual within 90 days of receipt by the controlling individual of a notice issued by the Minister under subsection 207.06(4); (c) a benefit that is income (determined without reference to paragraph 82(1)(b)), or a capital gain, that is reasonably attributable, directly or indirectly, to (i) a prohibited investment in respect of the registered plan or any other registered plan of the controlling individual, (ii) in the case of a registered plan that is not a TFSA, an amount received by the controlling individual of the registered plan, or by a person who does not deal at arm’s length with the controlling individual (if it is reasonable to consider, having regard to all the circumstances, that the amount was paid in relation to, or would not have been paid but for, property held in connection with the registered plan) and the amount was paid as, on account or in lieu of, or in satisfaction of, a payment (A) for services provided by a person who is, or who does not deal at arm’s length with, the controlling individual of the registered plan, or (B) of interest, of a dividend, of rent, of a royalty or of any other return on investment, or of proceeds of disposition, or (iii) a deliberate over-contribution; (d) a registered plan strip in respect of the registered plan; and (e) a prescribed benefit.  ... Liability for tax (3) Each controlling individual of a registered plan in connection with which a tax is imposed under subsection (1) is jointly and severally, or solidarily, liable to pay the tax except that, if the advantage is extended by the issuer, carrier or promoter of the registered plan or by a person with whom the issuer, carrier or promoter is not dealing at arm’s length, the issuer, carrier or promoter, and not the controlling individual, is liable to pay the tax. ... (c) Purpose [49] The Appellant’s purposive arguments centre on the purpose of the TFSA Charge, and, in connection to it, its effect. ...