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The Queen, 2013 DTC 1203 [at at 1083], 2013 TCC 247 (Informal Procedure)-- summary under Business Source/Reasonable Expectation of Profit Summary Under Tax Topics- Income Tax Act- Section 3- Paragraph 3(a)- Business Source/Reasonable Expectation of Profit LP for daughter's tennis training expenses When his daughter was nine years old, the taxpayer created the "Tennis Mania LP," which used the funds contributed by him to reimburse him for expenses incurred by him in connection with her training and development as a tennis player. ...

Detroit did not constitute part of the metropolitan area of Windsor as it was not integrated with the City of Windsor: "for example, there are no common infrastructures, municipal services such as streets, water, fire or police protection, and there is no political connection." ...

A submission that the land had originally been acquired for use in connection with an exotic cattle operation was rejected given that the land was known to be in the path of development, the price paid for the land greatly exceeded what one would expect from a purchaser looking for farming land, the partnership agreement among the taxpayers described them as "land developers", and not all the participants in the cattle operation were invited to participate in the land venture. ...

The Queen, 2007 TCC 306-- summary under Subsection 169(1) Summary Under Tax Topics- Excise Tax Act- Section 169- Subsection 169(1) Woods, J. accepted that an agreement pursuant to which the appellant ("YSI") agreed to contract with suppliers in connection with refurbishing a yacht and to charge the other party to the contract ("Platinum") a 5% mark-up on some of the purchases, did not establish an agency relationship between YSI and Platinum. ...

., [1982] BTC 417, [1983] 1 All E.R. 133 (HL)-- summary under Paragraph 153(1)(a) Summary Under Tax Topics- Income Tax Act- Section 153- Subsection 153(1)- Paragraph 153(1)(a) carrying on trade was sufficient connection to jurisdiction nS.204(1) of the Income and Corporation Taxes Act 1970 stated baldly that "income tax shall... be deducted or repaid by the person making payment" without (like s. 153(1) of the Canadian Act) stating explicitly that the payor, to be subject to this withholding obligation, must be a resident of or carrying on business in the jurisdiction. ...

In connection with noting that the children had not disclaimed their interests in the RRSPs, V. ...

The Queen, 2014 DTC 1126, 2013 TCC 310-- summary under Evidence Summary Under Tax Topics- General Concepts- Evidence Canadian tax accountant's testimony on US tax consequences accorded little weight The taxpayer sought to establish through testimony of a Canadian tax accountant who had advised in connection with the transactions under review that an arm's length vendor (Ford U.S.) of debt and shares to the taxpayer had engaged in preliminary transactions for U.S. tax reasons rather than to accommodate a Canadian tax advantage to the taxpayer. ...

A cash payment of $480,900 that reimbursed the City for related expenditures was a capital expenditure because it was made by the taxpayer in connection with expanding the parking capacity of the shopping centre, i.e., for the purpose of expanding the taxpayer's operating structure. ...

., after noting that both parties to the appeal accepted that the taxpayer's interest in a piece of undeveloped land was held in connection with an adventure or concern in the nature of trade ("a legitimate "scheme for profit-making',") indicated his agreement with this characterization, finding (at para. 18) that the critieria in IT-218R as to what is a real estate adventure in the nature of trade were satisfied: The apellant and his associates purchased the Styles Proprty with the intention of reselling it at a profit.... ...

Accordingly, although the appreciation in the value of land between 1970 (when it was acquired with a view to possibly reselling it at a gain) and 1976 was on income account, the appreciation from 1976 (when the taxpayer along with an affiliated company commenced to develop the land for use in connection with the construction of twin office towers) and 1983 (when the two buildings were sold pursuant to the acceptance of unsolicited offers at a price substantially in excess of the properties' fair market value) occurred on capital account. ...