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After quoting inter alia (at para. 45) from Marcel Widrig that the quoted wording requires “effective personal attachment to a territory,” Brooks J stated (at para. 62): [T]he construction of Article 4 advanced by HMRC requires both worldwide taxation and a connection or attachment to the contracting state concerned. In my judgment, this is the correct approach as it takes into account the common feature or similarity of domicile, residence, citizenship etc, in the context of the Convention, ie that they are all criteria providing, in addition to the imposition of a worldwide liability to tax, a “ connection ” or “ attachment ” of a person to the contracting state concerned. ... [emphasis in original] Brooks J went on to finding that the mere stapling of the GEFI stock did not give rise to the required connection. ...

It was paid in connection with the Appellant’s granting of the easement on his property. ...

In finding that the HST incurred by Look on its related litigation costs qualified for input tax credits by virtue of being incurred in connection with the termination of its commercial activity so as to engage s. 141.1(3), Webb J.A. stated (at paras 17, 18 and 34): …[T]he litigation should be characterized as a claim for overpaid remuneration. ... Therefore, there is a connection between the termination of Look’s commercial activity and the legal services acquired in relation to the litigation against the Former Executives that would be sufficient to permit Look to claim the input tax credits …. ... However, if the registrant is acquiring a property or a service in connection with the acquisition, establishment, disposition or termination of a commercial activity, that person will not lose the entitlement to claim an input tax credit solely because that person is not making any taxable supplies at the time that such property or service is acquired. ...

Canada, [2000] GSTC 109 (FCA)-- summary under Subsection 169(1) Summary Under Tax Topics- Excise Tax Act- Section 169- Subsection 169(1) cloth acquired to be made into farming work clothes was acquired in connection with the farming commercial activity In finding that heavy cloth purchased by a Hutterian colony (which was engaged in a farming business) to be made into work clothes for its members was eligible for the ITCs claimed by the colony for 50% of the GST payable on the purchases, Malone J.A. indicated (at para. 25): Once an item is found to be acquired and used in connection with the commercial activities of a GST registrant and that item directly or indirectly contributes to the production of articles or the provision of services that are taxable, then an ITC is available using the formula in that subsection. In a dissenting opinion, Evans J.A. agreed with the majority that "for the goods to be acquired for use 'in the course of commercial activities', there must be a functional connection between the needs of the business and the goods" (para. 31), but disagreed as to whether the connection was sufficient on the present facts. ...

Canada, 2010 DTC 5101, 2010 FCA 159-- summary under Territorial Limits Summary Under Tax Topics- Statutory Interpretation- Territorial Limits no filing requirement if no connection with Canada Nöel, J.A. noted (at para. 23) that when s. 150(1) formerly simply provided that in the case of a corporation, a return shall be filed by a corporation for each taxation year, "with respect to non-resident corporations, the obligation to file could only extend to those that had some connection with Canada. To construe the provision as applying in the absence of any connection with Canada would give it a reach that could not have been intended. ...

The Queen, 97 DTC 342 (TCC)-- summary under Eligible Capital Expenditure Summary Under Tax Topics- Income Tax Act- Section 14- Subsection 14(5)- Eligible Capital Expenditure Professional fees incurred in connection with a share reorganization of the taxpayer in which its shareholders transferred their shares to a holding company were found not to be incurred in connection with any activities which formed part of the business by which the taxpayer earned income and were incurred in connection with its dealings with its own shareholders as shareholder. ...

This program was found not to be undertaken as part of her duties of employment or "in connection with" her duties of employment but, rather, was undertaken in connection with her profession. ... Words and Phrases in connection with ...

In finding that the taxpayer was not "controlled, directly or indirectly in any manner whatever, by one or more non-resident persons", Sexton J.A. noted (at para. 33) authorities suggesting "that a common connection must exist amongst the majority shareholders in order for them to compose a 'group of persons'," found that the quoted phrase was synonymous to control by a non-resident person or group of non-resident persons, that "'control' necessitates that there be a sufficient common connection between the several persons referred to in that definition in order for there to be control by those several persons" (para. 35) and that "the common connection might include, inter alia, a voting agreement, an agreement to act in concert, or business or family arrangements" (para. 36). Here, there was no evidence of any common connection among the non-resident shareholders. ...

The Queen, 97 DTC 342 (TCC)-- summary under Legal and other Professional Fees Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Legal and other Professional Fees Professional fees incurred in connection with a share reorganization of the taxpayer in which its shareholders transferred their shares to a holding company were found not to be incurred in connection with any activities which formed part of the business by which the taxpayer earned income and were incurred in connection with its dealings with its own shareholders as shareholder. ...

., 74 DTC 6180, [1974] CTC 209 (FCA)-- summary under Paragraph 20(1)(e) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(e) In connection with the interim construction of a building, the taxpayer agreed in 1962 to pay interest on the borrowed money at a rate of 9%, plus "additional interest", in each of the 25 years after 1964 in which it was profitable, of 1% of its gross rental income from the building. ... "What appears to me to be the test is whether the expense, in whatever taxation year it occurs, arose from the issuing or selling or borrowing... the words 'in the course of' in section 11(1)(cb) are not a reference to the time when the expenses are incurred but are used in the sense of 'in connection with' or 'incidental to' or 'arising from' and refer to the process of carrying out or the things which must be undertaken to carry out the issuing or selling or borrowing for or in connection with which the expenses are incurred" (p. 6183). ...