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Counsel therefore have asked me to determine this issue as a preliminary to the consideration of any of the disputed documents. ... Euroclean did not report this deemed gain allegedly in breach of the foregoing provisions. 69.(1) Inadequate considerations. — Except as expressly otherwise provided in this Act, b) where a taxpayer has disposed of anything (i) to a person with whom he was not dealing at arm’s length for no proceeds or for proceeds less than the fair market value thereof at the time he so disposed of it, or (ii) to any person by way of gift inter vivos, he shall be deemed to have received proceeds of disposition therefor equal to that fair market value; It is the Crown's position that the transaction of purchase and sale of the Victoria Street property was not at arm's length, although not between related persons". ...

Such a view, however, ignores that the authorities might delay a consideration of or the bringing of a criminal prosecution in order to obtain financial information based on Demands made of the accused under the ITA that would support or be used in a derivative manner in- criminal investigation or prosecution, which is the end purpose of a special investigation initiated by the said memorandum. 66 In R. v. ...