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All additional costs to the purchaser in connection with tangible personal property attracts tax once it reaches Manitoba. ... I know that The Revenue Tax Act, RSM 1970, Cc R150 speaks of ‘all additional costs to the purchaser in connection With tangible personal property”. ... Exact parity may be impossible to achieve; the determination whether such and such a cost is incurred “in connection with the property” within the meaning of the Revenue Tax Act will depend on all the circumstances and there may well be borderline cases. ...

It is the Minister’s contention: that the taxpayer incurred the expenses which gave rise to the aforesaid losses in the said taxation years as personal or living expenses in connection with the maintenance and upkeep of his 72.40- acre farm property situated in the vicinity of Orangeville, Ontario, for the use or benefit of himself, his wife and children; that personal or living expenses are not allowed as a deduction in computing income under paragraph 12(1)(h) of the Income Tax Act, RSC 1952, c 148 as amended: that, pursuant to paragraph 139(1)(ae) of the said Act, “personal or living expenses” include the expenses of a property maintained by a taxpayer for the use or benefit of himself, his wife and children and not maintained in connection with a business carried on for profit or with a reasonable expectation of profit, and that, since the present taxpayer’s above-mentioned farm property was not maintained in connection with a business of the type outlined above, the said alleged farming losses had been properly disallowed in the taxation years specified. ... So, the overall cost of the taxpayer’s country home located on Pt E 1/2 Lot 7 Con 2 W Mono Twp amounted to over $41,000 excluding the cost of the land used in connection therewith. ... Since the appellant specifically pleaded the “hobby farm” subsection 13(1) of the Act, reference should be had to paragraph numbered 4 of the Kunkel case (supra) which makes it clear that, before a taxpayer can bring himself within that provision, he must be able to establish that his farm property was maintained by him “in connection with a business carried on for profit or with a reasonable expectation of profit” within the meaning of paragraph 139(1)(ae) of the Act. 7. ...

Although no precise data were supplied by the Appellant in connection with the use of the boat in 1997, the Appellant stated that he “almost broke even”. ... The Appellant asserted that in connection with the Innovative Industries operation he had been involved in many different endeavours over the years. ... I do not even accept that the Appellant spent the hours that he mentioned in his evidence in connection with this operation. ...

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. ... On the facts before me, there is a sufficient connection between the receipt of the money by Mr. ...

ANAYLSIS [8]            The amount of $22,148.00 is made up of a number of cheques issued by Carpet City either to George Mitzelos to the Royal Bank (re C.I.B.C.) or to the Royal Bank re the Appellant's visa account. [9]            The Appellant and the Appellant's wife testified that many of the cheques issued to the Royal Bank of Canada by Carpet City were issued in connection with a line of credit obtained by the Appellant to enable him to purchase an automobile. ... However, until the Appellant was fired by Carpet City effective February 14, 1997, there was never any suggestion that the Appellant should repay the amounts that had been provided to him by Carpet City in connection with the line of credit or car loan that he had obtained from the Royal Bank of Canada. ... Lutwak (or Carpet City) attempted to have the Appellant subject to tax on all of the said car payments plus other items. [11]          The Appellant and his wife also testified that the Appellant was required to use his automobile on a daily basis in connection with his position as a salesman/buyer for Carpet City. ...

In this connection, see the decision of Cameron, J. in Vancouver Towing Company Limited v. ... Charles Hotel Limited Standard Profits Claim In connection with the 8.P. 1 Claim of St. ... It is therefore unnecessary to deal with the cases and authorities cited by him in this connection. ...

A deduction cannot be so far removed from its corresponding income stream as to render its connection to the anticipated income tenuous at best ... (emphasis added)       [15]            It may be relatively easy to establish a sufficiently close connection between an interest-free loan by a shareholder and an anticipated dividend. ... As the Judge pointed out, the direct connection was between the expenses and the business of the corporations.   ...

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. ... In general, a taxpayer who moves is permitted to deduct moving expenses if the move is made in connection with the commencement of employment at a particular location in Canada. ...

The entitlement to reduce the standby charge in this fashion is only available where the automobile is used all or substantially all of the time in connection with the employment. ... Accordingly, the appeals are allowed and the assessments are referred back to the Minister for reassessment in accordance with subsections 6(2) and 6(2.1) of the Act on the basis that the taxpayer was required by the employer to use the automobile in connection with his employment and that all or substantially all of the distance travelled by the automobile in the total available days was in connection with or in the course of the employment. ... Sarchuk Appearances Agent for the Appellant:             Jerry Lupkowski Counsel for the Respondent:      Sidney Restall JUDGMENT           The appeals from assessments of tax made under the Income Tax Act for the 1995, 1996 and 1997 taxation years are allowed, without costs, and the assessments are referred back to the Minister of National Revenue for reconsideration and reassessment on the basis that pursuant to subsections 6(2) and 6(2.1) of the Act, the Appellant was required by the employer to use an automobile in connection with his employment and all or substantially all of the distance travelled by the automobile in the total available days was in connection with or in the course of the employment. ...

(b) during the 1994 and 1995 taxation years, the Appellant had available for use an automobile leased or paid for by the Employer (the "Company's Vehicles"), and was required to record the kilometres she travelled during each year; (c) during the entire 1994 and 1995 taxation years, the Appellant received and enjoyed the use of the Company's Vehicle; (d) the Appellant failed to maintain proper records for the use of the Company's Vehicle; (e) in each of the 1994 and 1995 taxation years, at least 12,000 kilometres of the distance travelled by the Company's Vehicle was not in connection with or in the course of the Appellant's employment; (f) the Employer paid all expenses related to the operation of the Company's Vehicle throughout the 1994 and 1995 taxation years; (g) for the 1994 and 1995 taxation years, the Employer conferred a benefit on the Appellant in respect of the personal use of the Company's Vehicle in the total amounts of $5,043 and $5,844 respectively. [3] At the commencement of the hearing, the parties advised the Court that the assessment with respect to the 1995 taxation year was no longer in issue. ... (e) where the taxpayer's employer or a person related to the employer made an automobile available to the taxpayer, or to a person related to the taxpayer, in the year, the amount, if any, by which (i) an amount that is a reasonable standby charge for the automobile for the total number of days in the year during which it was made so available exceeds (ii) the total of all amounts, each of which is an amount (other than an expense related to the operation of the automobile) paid in the year to the employer or the person related to the employer by the taxpayer or the person related to the taxpayer for the use of the automobile; 6(2) For the purposes of paragraph (1)(e), a reasonable standby charge for an automobile for the total number of days (in this subsection referred to as the “total available days”) in a taxation year during which the automobile is made available to a taxpayer or to a person related to the taxpayer by the employer of the taxpayer or by a person related to the employer (both of whom are in this subsection referred to as the “employer”) shall be deemed to be the amount determined by the formula A/B x [2% x (C x D) + 2/3 x (E- F)] where A is the lesser of (a) the total number of kilometres that the automobile is driven (otherwise than in connection with or in the course of the taxpayer's office or employment) during the total available days, and (b) the value determined for B for the year under this subsection in respect of the standby charge for the automobile during the total available days, except that the amount determined under paragraph (a) shall be deemed to be equal to the amount determined under paragraph (b) unless (c) the taxpayer is required by the employer to use the automobile in connection with or in the course of the office or employment, and (d) all or substantially all of the distance travelled by the automobile in the total available days is in connection with or in the course of the office or employment; Analysis [8] The relevant provisions of the Act require an employee who enjoys a benefit as a result of the employer paying operating expenses to include it in income. ... The entitlement to reduce the standby charge in this fashion is only available where the automobile is used all or substantially all of the time in connection with the employment. ...