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With respect to the co-ordinator, paragraph 8(1)(a) of the Act sets out an exclusion where the taxpayer is employed in the year by the employer "in connection with the performance of any of the duties referred in subparagraph (ii) or similar duties" (subparagraph (ii) refers to an ambulance technician, or a firefighter, or a person who assists in the search or rescue of individuals or in other emergency situations"). ... The Individuals may also visit schools, be available at certain events in case medical services are required, take additional training courses, or attend meetings in connection with the medical services they provide. ... Specifically excluded are employees, who are employed in the year, otherwise than as a volunteer by the employer, in connection with the duties referred to. ...

Using this approach  24(1) 24(1) Deductibility under paragraph 20(1)(e) 24(1) The test in Yonge-Eglinton Building Ltd. v MNR (supra), is that the expenses are incurred "... in connection with... ... " the borrowing. 24(1) As emphasized by the preamble to subsection 20(1) there must be a clear connection between the amount to be deducted and the source of the borrowing.  24(1) We also note 19(1) quotation of a passage from the same case which indicates that paragraph 20(1)(e) has a very broad scope because the section specifically excludes commissions and bonuses and payments as or on account of principal and interest.  ... Deductibility as a discount 24(1) Expenses related to financial reporting In our opinion, expenditures, if any, incurred to issue financial reports to shareholders to inform them of the loan restructuring should be deductible under subparagraph 20(1)(g)(iii), including the cost of obtaining the necessary legal and financial advice in connection with the issuance of financial reports. ...

You submit that, under the plan, contributions would be made by the particular employer to a trustee (custodian) in connection with benefits that may be received by a person on the loss of an office or employment of a taxpayer and, as such, you believe that the Trust would qualify as a "retirement compensation arrangement" ("RCA") as  that term is defined in subsection 248(1) of the Income Tax Act (Canada) (the "Act"). ... Generally, an RCA is an arrangement under which contributions are made by an employer to a custodian to fund an amount to be paid to an employee in connection with benefits to be received on, after or in contemplation of     (a)  any substantial change in the services rendered by the employee,     (b)  the employee's retirement, or     (c)  the loss of the employee's office or employment. ... In our view, the payments to be made to the custodian by the employer are being made to indemnify the directors and officers of the employer in respect of their personal obligations under the proposed amendments to the Employment Standards Act of Ontario and are not made in connection with benefits that are to be or may be received or enjoyed by an employee of the employer on, after or in contemplation of any of the circumstances set out in (a), (b) or (c) above. ...

Loveday File No. 5-8295 Subject:  24(1)  Individual Policyholders' Taxation on Surrenders of Life Insurance Policies We are writing in connection with your memoranda of June 22 and July 31, 1989.  ... Abdulhusein and B.Dodd, October 12, 1989), we are providing you with our comments on  24(1) April 20, 1989 letter and understand that you will reply directly to: 24(1) We apologize for the delay. 24(1)  has requested the Department's views in connection with a worksheet for the calculation of the amount to be included in income under subsection 148(1) of the income Tax Act (the "Act"). 24(1) Item 1) The overall approach being taken by 24(1) (as evidenced by items 1), 2) and 3) collectively), appears to be based somewhat on the method described in the Department's paper on the calculation of the adjusted cost basis ("ACB") for life insurance policies (prepared by G. ... The second component of Item 3), being policy loans after March 31, 1978 was discussed above in connection with item 2) The third component of Item 3), being annual dividends after March  31, 1977 (the date should actually be the MTA), including, termination dividends, and the descriptions thereof contained in 24(1) letter, reflect the appropriate treatment for policy under the Act.  ...

MNR [[1974] C.T.C. 209] (supra), is that the expenses are incurred "... in connection with... ... As emphasized by the preamble to subsection 20(1) there must be a clear connection between the amount to be deducted and the source of the borrowing. ... Deductibility as a discount XXX Expenses related to financial reporting In our opinion, expenditures, in any, incurred to issue financial reports to shareholders to inform them of the loan restructuring should be deductible under subparagraph 20(1)(g)(iii), including the cost of obtaining the necessary legal and financial advice in connection with the issuance of financial reports. ...

As indicated in our telephone discussion with you on April 25, we do not intend to communicate with XXX in connection with this matter other than to advise them that we shall be providing you with our views. Facts It is our understanding that the relevant facts in connection with this matter are as follows: 1. ... Ct.), dismissed on another issue, (1969), 23 DTC 5203 (SCC) determined that the length of time during which a debt is outstanding is irrelevant and thus seems to have determined that whether or not a debt is "permanent" financing is irrelevant for purposes of determining whether foreign exchange gains and losses in connection therewith are on income account or capital account. ...

Loveday 5-8295 24(1) Individual Policyholders' Taxation on Surrenders of Life insurance Policies We are writing in connection with your memoranda of June 22 and July 31, 1989. ... Abdulhusein and B.Dodd, October 12, 1989), we are providing you with our comments on 24(1) April 20, 1989 letter and understand that you will reply directly to: We apologize for the delay. 24(1) has requested the Department's views in connection with a worksheet for the calculation of the amount to be included in income under subsection 148(l) of the income Tax Act (the "Act"). 24(1) Item 1) The overall approach being taken by 24(1) (as evidenced by items 1), 2) and 3) collectively), appears to be based somewhat on the method described in the Department's paper on the calculation of the adjusted cost basis ("ACB") for life insurance policies (prepared by G. ... The second component of Item 3), being policy loans after March 31, 1978 was discussed above in connection with item 2) The third component of Item 3), being annual dividends after March 31, 1977 (the date should actually be the MTA), including, termination dividends, and the descriptions thereof contained in 24(1) letter, reflect the appropriate treatment for policy under the Act. ...

The first exception that would apply to automobile allowances is provided for in subparagraph 6(1)(b)(v) of the Act, which exempts from income reasonable allowances for travelling expenses received by an employee from his employer in respect of a period when he was employed in connection with the selling of property or negotiating of contracts for his employer. The second exception for automobile allowances is subparagraph 6(1)(b)(vii.1) of the Act which exempts allowances (not in excess of reasonable amounts) for the use of a motor vehicle received by an employee (other' than an employee employed in connection with the selling of property or negotiating of contracts for his employer) from his employer for. travelling in the performance of the duties of his office or employment. However, under subparagraph 6(1)(b)(x) of the Act, a motor vehicle allowance is deemed to be in excess of a reasonable amount where the measurement of the use of the vehicle for the purpose of the allowance is not based solely on the number of kilometres for which the motor vehicle is used in connection with or in the course of his office or employment. ...

Using this approach 24(1) 24(1) Deductibility under paragraph 20(1)(e) 24(1) The test in Yonge-Eglinton Building Ltd. v MNR (supra), is that the expenses are incurred "... in connection with... ... " the borrowing. 24(1) As emphasized by the preamble to subsection 20(1) there must be a clear connection between the amount to be deducted and the source of the borrowing. 24(1) We also note 19(1) quotation of a passage from the same case which indicates that paragraph 20(1)(e) has a very broad scope because the section specifically excludes commissions and bonuses and payments as or on account of principal and interest. ... Deductibility as a discount 24(1) Expenses related Co financial reporting In our opinion, expenditures, if any, incurred to issue financial reports to shareholders to inform them of the loan restructuring should be deductible under subparagraph 20(1)(g)(iii), including the cost of obtaining the necessary legal and financial advice in connection with the issuance of financial reports. ...

(Quotation is from the preamble of the provisions of subsection 62(1)) In 1972, Technical Interpretations Division advised Administrative Policy Branch that, although the allowance provided to Revenue Canada employees in respect of moving expenses was taxable within the strict interpretation of paragraph 6(1)(b), the allowance could be considered non-taxable if the employee was required to certify that expenses in the amount of the allowance were incurred in connection with the move for which no other reimbursement was available. ... However, since the inception of Section 62 we have always maintained that, where a member of the Armed Forces claimed moving expenses for which he was not fully reimbursed, he must reduce this claim by the amount of the allowance that was received in connection with his employer imposed relocation. ... You are now prepared to take the position that the allowance of either $150 or $500 paid by the Department of National Defence and the allowance of either $100, $200 or $500 paid to employees of other Federal Government Departments for moving expenses that are not deductible under section 62 should not be included in income for purposes of paragraph 62(1)(g) where the allowance is considered to be a non-taxable reimbursement because the employee certifies that expenses in the amount of the allowance were incurred in connection with the move for which no other reimbursement was available. ...