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The Queen, 93 DTC 5217, [1993] 1 CTC 245 (FCTD)-- summary under Paragraph (g) Summary Under Tax Topics- Income Tax Act- Section 66.1- Subsection 66.1(6)- Canadian exploration expense- Paragraph (g) Expenses incurred by members of a joint venture, including the taxpayer, in connection with preliminary planning for an underground mine that was located in the same coal seam as an existing surface mine, and expenses incurred in developing the underground mine, qualified under subparagraphs (iii) and (iii.1). ...

Therefore…the grant of the proxy…is insufficient to demonstrate a common connection…. ...

., 2004 DTC 6475, 2004 FCA 234-- summary under Subsection 248(10) Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(10) a transaction with an independent purpose and existence nonetheless can form part of a common law series Normal course dividends paid by two public corporations (“CU” and “CUH”) which gave rise to a Part IV tax refund were considered part of the series of transactions that included s. 85(3) deemed to be received by CU and CUH in connection with a reorganization of another public company (“ATCOR”) and an acquisition by a third party (“Forest”) because, although they had an independent purpose and existence, they were part of the series of transactions that included such deemed dividends received by CU and CUH, and were appropriately assessed pursuant to s. 55(2). ...

The Queen, 93 DTC 5457, [1993] 2 CTC 266 (FCTD)-- summary under Disposition of Property Summary Under Tax Topics- Income Tax Act- Section 13- Subsection 13(21)- Disposition of Property no transfer of title or all the incidents of title In connection with the sale of the taxpayer's business to an arm's length corporation, it was agreed that refillable cylinders would be rented by the taxpayer to the purchaser at, what was found on the evidence to be, a market rate of rent, and that over the subsequent five years, 1/5 of the cylinders would be purchased each year by the purchaser for a stipulated amount. ...

Hershfield J. found that the taxpayer did not demonstrate sufficient connection to the reserve for the years in question. ...

In finding that various legal and other fees incurred by the taxpayer in connection with the oppression remedy and various collateral actions were deductible, Archambault T.C.J. noted that the taxpayer's purpose was to receive more income for a relatively short period of time and that in applying for a remedy against oppression, the taxpayer was only exercising its right created by a statute rather than seeking the creation of a new right. ...

After all, the connection of Explanatory Notes with the shape of the proposed legislation is closer than pre-parliamentary aids which in principle are already treated as admissible: see Cross, Statutory Interpretation, 3rd ed (1995), pp 160-161. ...

The funding was received in connection with the enrolment. It was clear that "PSC did not provide the funding to the appellants in a vacuum" (para. 35). ...

This was not... retaining any investment existing at the time of his death, for investment is not a proper term as to monies in trade, and the testator has not used it in any popular sense, because he speaks of investing in connection with securities and does not regard his business as an investment. ...

The underwriting commissions constituted an "outlay or expense" under the definition that was paid for services rendered by the underwriter in connection with pricing, distributing and managing the public issue of its shares, rather than a discount, notwithstanding that there was a firm underwriting. ...