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The Queen, 2011 DTC 1163 [at at 873], 2011 TCC 213-- 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 improved tax efficiency was enduring (3 year) benefit The taxpayer incurred legal and accounting fees in 1997 and 1998 of approximately $1.9 million in connection with a complicated reorganization of the manner in which it financed its investment in its US subsidiaries. ...

He also noted that the words "directly" and "in connection with" mean "activities which, first, are connected with manufacturing and processing operations in Canada but are not an integral part of the actual manufacturing and processing process" (p. 2258). ...

Humber (also involving a CNA-Q instructor) was distinguished on the basis that there the connection between CNA's activities and oil exploitation had not been adequately established. ...

President Jackett stated: "No communication, statement or other material made or prepared by an accountant as such for a business man falls within the privilege unless it was prepared by the accountant as a result of a request by the business man's lawyer to be used in connection with litigation, existing or apprehended; and... ...

The Queen, 2012 DTC 1190 [at at 3488], 2012 TCC 212 (Informal Procedure)-- summary under Paragraph 56(1)(n) Summary Under Tax Topics- Income Tax Act- Section 56- Subsection 56(1)- Paragraph 56(1)(n) dominant character of payments made to post-doctoral fellow was compensation for research work The taxpayer sought an exemption under s. 56(1)(n) in respect of income from the Ontario Health Research Institute ("OHRI") in connection with a postdoctoral fellowship at the University of Ottawa. ...

., 99 DTC 5358, [1999] 3 CTC 520 (FCA)-- summary under Subsection 93(1) Summary Under Tax Topics- Income Tax Act- Section 93- Subsection 93(1) s. 93 deeming a dividend in kind of a note to be a dividend received precluded a subsequent bad debt claim for the note In connection with the liquidation of a U.S. corporation owned by the two Canadian corporate taxpayers, they received promissory notes owing by another U.S. corporation and cash, and elected under s. 93(1) in respect to the distribution. ...

In connection with matrimonial litigation, the Class A share of the appellant was found to have a fair value of $150,000 rather than the $10,000 figure advanced by the appellant, in light of its entitlement to 1/2 the net property on a winding-up and in light of the entitlement of a holder of that share to hire himself as a manager of the farm and pay himself reasonable remuneration for its services, without fear of being dismissed and without the obligation to consult or take instructions from anyone. ...

A proposed structure on a site which it planned to rent to tenants was therefore intended to be used in connection with its business, i.e., renting out a property is a "use" of property. ...

., 64 DTC 5184, [1964] CTC 294 (Ex Ct)-- summary under Subsection 15(1) Summary Under Tax Topics- Income Tax Act- Section 15- Subsection 15(1) no "conferral" if corporation is advancing its business In 1953 two subsidiaries of the taxpayer waived the interest that was coming due on two loans they had made to the taxpayer a year previously, and a year later all the further interest was waived in connection with the repayment by the taxpayer of a portion of the principal in full satisfaction of the loans. ...

In finding that there have been no misrepresentation by the taxpayer in connection with not including these amounts in his income, Mr. ...