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I note the general nature of the remarks made by McIntyre J. in this connection. ... It is evident that the connection between the legislative objective and the means chosen exists more in theory than in practice. ... Having said that, I am not prepared to conclude that the impugned legislation entirely fails the rational connection test. ...

I say this because that individual first referred to is next referred to in connection with his family. ...

He manufactures his lumber for sale, and, as a general rule, would not manufacture any specific lumber for use in connection with his building contracts, but would simply take lumber for these purposes from the general stock manufactured for sale, and might thus, under the view taken in the court below, escape taxation on all lumber thus diverted from the general stock manufactured for sale. ...

In this connection— (i) An enterprise of one of the territories shall not be deemed to have a permanent establishment in the other territory merely because it carries on business dealings in that other territory through a bona fide broker or general commission agent acting in the ordinary course of his business as such; (ii) The fact that an enterprise of one of the territories maintains in the other territory a fixed place of business exclusively for the purchase of goods or merchandise shall not of itself constitute that fixed place of business a permanent establishment of the enterprise; (iii) The fact that a company which is a resident of one of the territories has a subsidiary company which is a resident of the other territory or which carries on a trade or business in that other territory (whether through a permanent establishment or otherwise) shall not of itself constitute that subsidiary company a permanent establishment of its parent company. ...

In the words of its counsel in his opening remarks at trial: (1) “scientific research expenditures incurred by it are of a capital and not of an income nature, and are not deductible in computing profits under the jurisprudential rules developed by the Courts over a period of many years in connection with the income tax.” (2) “scientific research expenditures are not related to the production of prime metal, and thereby are not deductible by virtue of the language of Regulation 1201.” ...

I mention these interest rates because there appears to be no connection between the size of the discount and an unduly low interest rate. ...

In my view there is not, and in that connection it is useful to refer to the statement of Viscount Simonds in Kirkness v. ...

Mackenzie the $500 a month provided by the third codicil, and nothing appears to have been paid to him in this connection until the 5th of March, 1927, when a lump sum of $19,500 was paid to him to cover the period from the date of the testator’s death to that date. ...

This connotes the existence of some sort of causal connection or, in the least, some relationship of proximity.  ... A person or entity is considered resident in a country if that country asserts an unlimited right to tax his or its income-- that is, a right based upon the taxpayer's personal connection with the country (as opposed to the source of the income or other income- or asset-related factors).  ... In this connection, I find persuasive the submission that only those corporations that are liable to taxation for the full amount of their world-wide income meet the definition of "resident" in the Canada-United States Income Tax Convention (1980).  ...

Male, [1891] 2 Q.B. 1, the taxpayer had loaned not as a permanent investment but, as stated in paragraph 6 of the statement of facts, ‘‘only in connection with the current dealings and transactions of the customer with the’’ taxpayer. ... Why, then, should the outlays in connexion with the present transactions, compendiously described as ‘refunding operations’, not also fall within the same category? ... In this connection it is important to observe that Ruling Number 15 is not a statutory provision, but rather a circular to provide direction and assistance to the officials of the Department. ...