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Davis had certain connections of a personal and economic nature. The largest value of Mr. ...

., 2018 FCA 124-- summary under Paragraph 20(1)(bb) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(bb) deduction was available for advisory fees respecting proposed acquisitin or divestiture of a whole company The taxpayer (“Alcan”), a Canadian public company listed on the TSX and NYSE and in Europe, incurred fees (mostly of investment dealers, law firms and a French lobbying and public relations firm in connection with its decision to make a hostile bid for a French public company (“Pechiney”) and the subsequent making and completion of that bid late in 2003. ...

The two issues were "the taxability issue"--whether the settlement sum was taxable employment income as "payments and other benefits which are received [by the relevant person] directly or indirectly in consideration or in consequence of, or otherwise in connection with- (a) the termination of a person's employment"; and, if so, "the exemption issue"--whether the settlement sum (or any part of it) was taken out of the above charge to tax by a statutory exemption (“s. 406”) for a payment provided "on account of injury to … an employee", the alleged injury being the injury to the taxpayer's feelings sustained in the context of his age discrimination claim. ...

., [2018] HCA 59-- summary under Paragraph (a) Summary Under Tax Topics- Income Tax Regulations- Schedules- Schedule II- Class 14.1- Paragraph (a) goodwill must have a connection to attracting custom Whether the acquisition by Barrick Gold Corporation ("Barrick") of another Canadian public company, namely, Placer Dome Inc. ...

The taxpayer ultimately pleaded guilty to trafficking charges but, in connection with sentencing, asserted that his involvement was quite limited and that he did not share in the profits. ...

Both were now Canadian citizens, and neither one has any real ongoing connection with the U.S. ...

In rejecting Roofmart’s reliance on the statement in Hydro-Québec that "[w]hen the group is generic and has no connection to the ITA, and information can be requested outside of the scope of the ITA (such as identifying the business clients of a public utility) there is no longer any limit on the fishing expedition," Rennie JA stated (at para 37) that this “passage is not a legal test but analysis of whether, on the facts of that case, there was an ‘ascertainable group’ and whether the information was required for the purposes of verifying compliance,” and that ”the suggestion in the reasons that the information sought was available through other means and therefore could not be obtained through a UPR is inconsistent with this Court’s jurisprudence, and ought not to be followed.” ...

Furthermore, on January 15, 1999, he was entitled to receive a $52,617 transitional allowance in connection with his electoral defeat, but with payment on this amount being stopped because an investigation had been initiated into the misuse of the 1998 payments received by the taxpayer. ...

The connection of the consumption or use of the Subject Services to the course of the employee’s employment activities is even more tenuous and remote in the situation where a spouse or a child of the employee received a Subject Service. ...

Before so concluding, she also noted (at para. 45): In order for multiple shareholders to collectively exercise de jure control of a corporation, there must be a sufficient common connection between them, such as in a voting agreement, an agreement to act in concert, or business or family relationships (Silicon Graphics...). ...