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Pursuant to these conditions, CDPQ's subscription was conditional on Laurentian Bank's reimbursement of certain fees and expenses to be incurred by CDPQ in connection with the subscription. ... It may not always be easy to decide whether an expense has so risen but it seems to me that the words "in the course of" in paragraph 11(1)(cb) [now paragraph 20(1)(e)] are not a reference to the time when the expenses are incurred but are used in the sense of "in connection with" or "incidental to" or "arising from" and refer to the process of carrying out or the things which must be undertaken to carry out the issuing or selling or borrowing for or in connection with which the expenses are incurred. ... "in connection with" or "incidental to" or "arising from". [76] In the light of this, an expense incurred in the course of an issuance of shares could be deductible pursuant to paragraph 20(1)(e) of the ITA insofar as the evidence shows that the expense was incurred by the taxpayer "in connection with" the issuance of shares of its capital stock or that it is an expense "incidental to" or "arising from" the issuance of the shares. ...

Furthermore, we would, as a general rule, expect that for any expense to be said to have been incurred for the purpose of determining the existence, etc. of petroleum or natural gas on a property, there would have to be at least some connection between that expense and work actually done on the ground. ... As I read those cases, the purpose test in the definition of "Canadian exploration expense" requires at least some connection between the purchased seismic data and actual exploration work. Evidence of the actual use of the seismic data for exploration could provide that connection. ...

Judge Porter decided each haircutter was involved in a business activity in connection with a hairdressing establishment and that each provided services that are normally provided therein. ... They import such meanings as "in relation to", "with reference to" or "in connection with". The phrase "in respect of" is probably the widest of any expression intended to convey some connection between two related subject matters. ...

The remedial and repair work were not directly related to the move but were incurred in connection with the move to preserve or enhance value. ... The Minister of National Revenue, [1] a decision of the Tax Review Board, as authority for the proposition that moving expenses embraced only those expenditures directly related to the sale of the old residence and not all expenses or costs incurred in connection with its sale ...

Whereas prolonged delays can obscure this connection and dilute the effectiveness of any disposition, timely intervention reinforces it. ... This is so for at least five reasons. [51]                          Reinforcing the connection between actions and consequences. ... Whereas prolonged delays can obscure this connection and “dilut[e] the effectiveness of any disposition”, timely intervention reinforces it (P. ...

I emphasize it is the connection that is paramount, not the timing of the activity. ... There is simply no such connection. [11]   The Tax Court judge also found that any connection between the litigation and the winding down of the corporation would not be sufficient to allow Look to claim input tax credits for the GST or HST paid in relation to the legal services provided in connection with the litigation against the Former Executives. ... However, there was a direct connection between the litigation and the source of the funds used to pay the Former Executives. ...

She explained that the calculation of a reasonable standby charge provided for in subsection 6(2) of the Act does not take into account the personal use percentage of total kilometrage except where the employer requires the taxpayer to use the automobile in connection with or in the course of a taxpayer's office or employment and if all or substantially all of the distance travelled by the automobile is in connection with or in the course of the office or employment. ... Second, "all or substantially all" of the distance travelled by the automobile during the time it was made available to the employee must be in connection with or in the course of his or her employment. ...   [20]    In connection to that percentage, reference must be made to a decision by our Court in McDonald v. ...

Abbott identified his grandfather, Roland Leonard Young, as his ancestral connection to the pre-Confederation Mi’kmaq community of Chance Port (Twillingate) and his current connection to Gander Bay South (Musgrave Harbour), an Annex B community. [81]   Mr. ... Abbott alleges that there is no rational connection between the date the “substantial connection” must be proven in the Directive and the date of the Agreement. ... (b)   Whether the requirement that the “substantial connection” go beyond family is arbitrary [173]   Mr. ...

Something more would be needed: some real connections to the country of residence. ... In the absence of such connections, the residence state’s greater claim to tax would retreat so that the connection between the source state and the immovable property would prevail. ... This connection between the income and the residence state forms the economic basis for residence state taxation. ...

.), by reason solely of the fact that more than 50% of the shares are held by non-resident persons where there is no evidence of any common connection among them. ... However, the critical issue here is whether a simple majority of shares held by non-residents leads to an inference of de jure control by those non-residents or whether some common connection or nexus must exist amongst those shareholders to support such an inference. [33]            A few cases have suggested that a common connection must exist amongst the majority shareholders in order for them to compose a "group of persons" for the purposes of the Income Tax Act. ... I also agree with the appellant's submission that in order for more than one person to be in a position to exercise control it is necessary that there be a sufficient common connection between the individual shareholders. ...