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Moreover, given that the costs had a clear connection to earning business income, the Court could not second-guess the taxpayers' business judgment. ...

Moreover, given that the costs had a clear connection to earning business income, the Court could not second-guess the taxpayers' business judgment. ...

The payment could not be characterized as a reimbursement for actual losses incurred by him in connection with the transfer. ...

The Court affirmed the finding of the trial judge that the maintenance of a small office on the reserve that was used principally for the purpose of distributing cheques to the Indian employees of the company, and the fact that the earning of remuneration or profits from the company had a general economic benefit for the reserve, were not sufficient connections to the reserve to establish exemption. ...

The Queen, 2009 DTC 1360, 2009 TCC 390-- summary under Start-Up and Liquidation Costs Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Start-Up and Liquidation Costs fledgling business should entail "serious and reasonable continuous efforts to begin normal operations" Various professional expenses that the taxpayer incurred with respect to a proposed venture of providing on-site mobile message therapy services to corporate clients through massage buses were found to have been incurred in connection with a business given that (para. 11): In this case it seems clear that Mr. ...

The payments were capital outlays since they established a permanent physical connection between the taxpayer's plant and the Anglo-Canadian plant, that enabled the taxpayer's plant to be readily and easily supplied with steam and pulp, and thereby increased the value and desirability of the taxpayer's plant. ...

This cannot be established "unless the evidence on oath furnishes some facts as to the nature of the seized documents and their connection with the violation in question- rather than insulating such facts from the judge's consideration under statements as to the deponent's opinion. ...

The Queen, 2009 DTC 1170, 2009 TCC 357-- summary under Subsection 163(2) Summary Under Tax Topics- Income Tax Act- Section 163- Subsection 163(2) In deleting a penalty for gross negligence assessed on the taxpayer in connection with a net worth assessment, Webb, J. stated (at para. 53) that: "While [the taxpayer] was careless or neglectful, I am not satisfied that the Respondent has established that he had the requisite mens rea to justify the imposition of the penalty under subsection 163(2) of the Act. ...

Canada, 2003 FCA 446-- summary under Subsection 169(1) Summary Under Tax Topics- Excise Tax Act- Section 169- Subsection 169(1) legal costs of shareholder too remote GST on legal services supplied to the applicant to enable him and his company to obtain damages from a bank for wrongfully calling in a loan to the company, thereby forcing it out of business, was not eligible for an input tax credit given that the applicant had not established a connection, direct or indirect, between his purchase of the legal services and any ongoing supply of taxable services. ...

The Queen, 97 DTC 517 (TCC)-- summary under Computation of Profit Summary Under Tax Topics- Income Tax Act- Section 9- Computation of Profit cost of shares acquired in consideration for largely worthless loan obligation was nil In connection with the acquisition of the shares of a corporation ("LTM") by another corporation ("HSS") of which the taxpayer was the general manager, the taxpayer used the proceeds of a daylight loan to advance money to LTM, LTM loaned the same sum to its shareholders, the shareholders loaned the same sum to the taxpayer on a non-interest bearing basis with the principal not being due for approximately 100 years, and the taxpayer used the sum to pay off the daylight loan. ...