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Because the taxpayer was already suspended from the practice of law when the fees were incurred, they could not have been incurred in connection with any commercial activity. The taxpayer's argued that referral fees he received for referring clients to other lawyers was a commercial activity entitling him to the input tax credits, but the Court found there was no connection between that activity and the fees he incurred in his criminal defence. ...

The Queen, 2013 DTC 1142 [at at 757], 2013 TCC 107 (Informal Procedure)-- 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 no connection with medical practice The taxpayer, a physician, sought retribution against an arbitrator who had ruled against her in a medical dispute. ... Hogan J found that the taxpayer's legal fees incurred in the arbitrator's suit were not a business expense, as there was no connection between the relevant legal expenses and the business. ...

., was found to continue to be a resident of Canada in those years given the connections that she has maintained with Canada (including maintaining her Ontario driver's licence, OHIP coverage, the utilization of the services of a Windsor doctor and dentist, membership in a yacht club and her ties with her husband and two children in the Windsor family home including the provision of support to the children) and the temporary nature of her connections to the U.S. including not entering into a lease or purchasing a home and instead sharing room with a relative or friend. ...

The Queen, 95 DTC 5585, [1995] 2 CTC 312 (FCTD)-- 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 Legal fees incurred by the taxpayer in defending against contempt charges did not have a sufficiently direct connection with an objective of reversing a suspension of his qualification to practise law given that a conviction of the taxpayer for obstruction of justice and counselling perjury might continue to bar him from regaining such qualification. Legal fees incurred by the taxpayer in connection with a suit claiming that third parties had misrepresented the quantity of sand and gravel to be extracted from a parcel of land sold to a corporation also were non-deductible because such suit concerned the corporation's business rather than his. ...

The Queen, 95 DTC 5058, [1995] 1 CTC 203 (FCTD)-- summary under Section 231.2 Summary Under Tax Topics- Income Tax Act- Section 231.2 The IRS requested assistance from Revenue Canada in connection with a criminal investigation of a client ("Lieberman") of the applicant, who was a BC barrister. ... Income Tax Convention notwithstanding that there was only oral disclosure that the information was requested by the U.S. tax authorities in connection with an income tax investigation of Lieberman pursuant to Article XXVII. ...

., 92 DTC 6123, [1992] 1 CTC 183 (FCA)-- summary under Paragraph (a) Summary Under Tax Topics- Income Tax Act- Section 66.1- Subsection 66.1(6)- Canadian exploration expense- Paragraph (a) no connection betweeen lease payments and exploration In finding that annual rental or other payments to provincial governments made for the purpose of keeping leases or licences to subsurface oil and gas rights current were not CEE, Hugessen J.A. stated (p. 6128): "... ... [T]here would have to be at least some connection between that expense and the work actually done on the ground... ...

In addition "in order for the taxpayer to be permitted [the deduction]...the person to whom the money is paid for the purpose of making the service connections must be the person who supplies the electricity, gas, telephone service, water or sewers for the supply of which connections are made. ...

MNR, 90 DTC 1050, [1990] 1 CTC 2141 (TCC)-- summary under Section 62 Summary Under Tax Topics- Income Tax Act- Section 62 In 1981 the taxpayer deducted expenses in moving from the family home in Montreal to a temporary residence in Edmonton and in 1983 he deducted further expenses incurred in connection with moving from Edmonton to Victoria to take up a new teaching position. It was held that he could not deduct in 1984 expenses incurred in connection with moving in 1984 his family's effects from the Montreal home to Victoria. ...

Although the purchase commissions were found to be dependent on sales of goods by manufacturers to Hasbro that were described in s. 212(1)(d)(iii)(B), by the same token they were excluded by the postamble: the phrase "in connection with" was clearly broader in its scope than the phrase "dependent on". Furthermore, at least some portion of the payments made was made for services in connection with the negotiation of a contract, and accordingly all the payment were exempt from withholding tax as the Minister had not designated which portion should be taxable under s. 212(1)(d)(iii). ...

Canada, 2009 DTC 5940, 2008 FCA 419-- summary under Cumulative Eligible Capital Summary Under Tax Topics- Income Tax Act- Section 14- Subsection 14(5)- Cumulative Eligible Capital A lump sum received by the taxpayer in consideration for the cancellation of a non-competition agreement that it previously had received in connection with an acquisition of a business as a going concern represented proceeds of "disposition" on general principles given that the agreement was extinguished, and also was received on capital account given that (from the perspective of the taxpayer) an acquisition of a non-competition agreement in connection with its business would have been on capital account. ...