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Law [13]         A commissioned sales employee can make deductions from her or his employment income only if the type of expense is specified under section 8 of the Act. [5] Each subsection stipulates that the employee must be required by her or his employer, under a contract of employment, to pay for the expenses in the year in the course of her or his employment. [14]         Paragraph 8(1)(f) authorizes the deduction of expenses up to the limit of commission income earned. [6] In addition to those conditions, the amounts must be expended by the employee in the year for the purpose of earning income from employment, and the employee must also:           (a)     be employed in the year in connection with the selling of property or negotiating contracts for her or his employer;           (b)     ordinarily be required to carry on duties of the employment away from the employer’s place of business;           (c)      be remunerated, in whole or in part,  by commissions; and           (d)     not be in receipt of a non-taxable travel allowance. [15]         A specified expense will only qualify as a deduction if the above conditions are met and the expense was:           (a)     not an outlay, loss or replacement of capital or payment on account of capital;           (b)     not an outlay or expense that is not deductible pursuant to paragraph 18(1)(l);           (c)      not an amount described in subparagraph 8(1)(f)(vii) in connection with standby charges for a vehicle; and           (d)     reasonable in the circumstances. [16]         The application of the purpose test in paragraph 8(1)(f) is similar though not identical to the business expenses purpose test. [7] The Supreme Court of Canada in Symes v Canada, [1993] 4 S.C.R. 695 (SCC), involving the later test, at paragraph 68, notes that in considering the purpose behind actions, courts should not be guided only by a taxpayer’s statements, ex post facto or as to the subjective purpose of an expenditure. ... Subsection 8(2) contains the g eneral limitation which reads “ E xcept as permitted by this section, no deductions shall be made in computing a taxpayer’s income for a taxation year from an office or employment. ”   [6]         Paragraph 8(1)(f) reads: 8 (1)      In computing a taxpayer’s income for a taxation year from an office or employment, there may be deducted such of the following amounts as are wholly applicable to that source or such part of the following amounts as may reasonably be regarded as applicable thereto … (f)                  where the taxpayer was employed in the year in connection with the selling of property or negotiating of contracts for the taxpayer’s employer, and … (i)         under the contract of employment was required to pay the taxpayer’s own expenses, (ii)        was ordinarily required to carry on the duties of the employment away from the employer’s place of business, (iii)       was remunerated in whole or part by commissions or other similar amounts fixed by reference to the volume of the sales made or the contracts negotiated, and (iv)       was not in receipt of an allowance for travel expenses in respect of the taxation year that was, by virtue of subparagraph 6(1)(b)(v), not included in computing the taxpayer’s income, amounts expended by the taxpayer in the year for the purpose of earning the income from the employment (not exceeding the commissions or other similar amounts referred to in subparagraph 8(1)(f)(iii) and received by the taxpayer in the year) to the extent that those amounts were not (v)        outlays, losses or replacements of capital or payments on account of capital, except as described in paragraph 8(1)(j), (vi)       outlays or expenses that would, by virtue of paragraph 18(1)(l), not be deductible in computing the taxpayer’s income for the year if the employment were a business carried on by the taxpayer, or           (vii)      amounts the payment of which reduced the amount that would otherwise be included in computing the taxpayer’s income for the year because of paragraph 6(1)(e); … [7]               That is, were the amounts expended by the taxpayer in the year for the purpose of earning income from employment ...

On account of its connection with Dorna, the applicant’s company allegedly received a visit from government agents in July 2004.  ... It is limited to the circumstances of this particular appeal and specifically the following factors:   (1)           The appeal is in regard to what has been described as the blunt instrument of a net worth assessment;   (2)           The cost is substantial in connection with the tax in issue;   (3)           The Appellant’s financial resources are prima facia limited;   (4)           The witness is outside North America;   (5)           The witness is not an expert;   (6)           The witness will not rely on any documentary evidence;   (7)           The testimony is limited in scope and is anticipated to be brief in duration; and   (8)           The witness must testify in the presence of a judge or lawyer of the foreign jurisdiction under oath in that jurisdiction ... Kashani’s situation and his connection to the applicant was the subject of discussions at the hearing (panel’s record, at pages 361 et seq.).               ...

All documents that had been circulated to parties other than the Applicants, their solicitors and agents were released to the CCRA pursuant to the requirement to produce. [7]                It appears from the affidavit evidence filed by the Applicants that the retained documents have not been circulated beyond the clients, lawyers retained by Heenan Blaikie and non legal professional advisors whose advice was sought in connection with the transaction. ... Counsel for the Respondent also acknowledged that correspondence between Heenan Blaikie and other lawyers retained by them in connection with the transaction are also subject to solicitor-client privilege. ... Wilder, Alliance Equicap Corp., to Norman Bacal, Heenan Blaikie, with handwritten notes, with attached tables re: term sheet; l)    document 470, fax cover sheet from Joseph Miller, Alliance, to Linda Rosenthal, Alliance, Norman Bacal, Heenan Blaikie (Toronto) and Jeff Berkowitz, Heenan Blaikie (LA), with attached draft financial statements of Alliance Services (No. 10) Limited Partnership for the period ended September 6, 1996. [36]            The following documents will be exempt from production on the basis that they represent communications between the Applicants' solicitors and agents, including other lawyers engaged to represent the interests of the Applicants in connection with the transaction, and non-legal agents, classification number 2: a) document 65, fax cover sheet from Nurhan Aycan, Heenan Blaikie to Mickey Rosenberg, Filmore & Riley, with attached letter from Filmore & Riley, to Alliance Equipcap Corporation, Heenan Blaikie, Limited Partners of AFS Limited Partnership No. 7, Internationale Nederlanden Bank N.V. and Warner Bros. dated November 7, 1995, fax cover sheet dated November 1, 1995; b) document 68, fax cover sheet from Jeffrey Berkowitz, Heenan Blaikie to Adam Kardash, Heenan Blaikie with attached draft letter dated November 2, 1995 from Price Waterhouse LLP to Alliance Services (No. 6) Limited. ...

  [5]    The CRA responded on July 14, 2010, refusing to release the said information under paragraphs 16(1)(a) and 16(1)(c) of the Access to Information Act, RSC 1985, c A-1 [ATIA], since the information had apparently been prepared and obtained in connection with an investigation ... There must be a clear and direct connection between the disclosure of specific information and the injury that is alleged.  ...   [55]            The Court must reject the interpretation proposed by the respondent, whereby the documents obtained in connection with a simple audit are automatically subject to the exemption in paragraph 22(1)(a) once they are placed in a fraud investigation file. ...

Accordingly, if that is the case, the appeal on the merits casts doubt on the motions judge"s conclusion that it was purely speculative that the documents would be used in connection with criminal proceedings. ... In this connection Hugessen J.A. wrote in Coppello: 9     ... On the first branch of that test as to whether or not there is a serious question to be tried, there is no doubt whatever that this application raises very serious and difficult questions. ... In this connection Stone J. wrote for this Court in New Brunswick Electric Power Commission and Maritime Electric Company Limited v. ...

  (6)    An order or direction that is made in the course of or in connection with any legal proceedings and that requires an official or authorized person to give or produce evidence relating to any taxpayer information may, by notice served on all interested parties, be appealed forthwith by the Minister or by the person against whom the order or direction is made to (a)    ... ... 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.   ...

Grenon’s allegation of a factual connection between the child support litigation and the Federal Child Support Guidelines, SOR/97-175, enacted under the Divorce Act, R.S.C., 1985, c. 3 (2nd Supp.): 11. ... Grenon’s attempt to discover evidence relating to the development of the Guidelines was a step too far, because the pleadings do not make a clear connection between the evidentiary foundation for the Guidelines, which is the subject of the disputed questions, and the disallowance of the legal expense deduction pursuant to paragraph 18(1)(a) of the Income Tax Act.   ... I see no error in Justice Miller’s interpretation of the pleadings, or in his specific finding that the pleadings do not allege a connection between the scope and application of paragraph 18(1)(a) and the analytical foundations of the Guidelines ...

In addition to this credit, Cybernius is also entitled to a $465,922.84 tax credit in connection with SRED credits. [9]                On September 14, 2015, Cybernius requested that the Minister first set-off the $594,854.58 reassessment credit owed to Cybernius against the $800,000.00 payroll source deductions owed by Cybernius. ... Cybernius seeks solicitor-client costs in connection with the application. ... Should the Applicant be awarded solicitor-client costs in connection with this application? ...

Given their breadth, it would not be fair to ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||, as the Prime Minister contends. [22]            Finally, I note that the exemption relating to discretionary financial benefits applies if the information in question merely “relates to” a financial benefit; all that is required is some link or connection to the financial benefit. In my view, that connection has been established here. [23]            Accordingly, in respect of the information PCO seeks to protect as personal information, I find that the exemption on which PCO relies is not applicable. [24]            It is therefore unnecessary to consider whether the public interest should override the exemption (PA, s 8(2)(m)(i)). ... Policy Requirements Exigences de la politique Approval authorities are responsible for: Les autorités approbatrices ont les responsabilités suivantes: … […] 6.1.5 Three basic eligibility criteria: In considering Crown servants for legal assistance or indemnification, determining whether the Crown servant: 6.1.5 Trois critères d’admissibilité de base: évaluer la demande de services juridiques ou d’indemnisation du fonctionnaire de l’État, en établissant si le fonctionnaire: •     acted in good faith; •     a agi de bonne foi; •     did not act against the interests of the Crown; and •     n’a pas agi à l’encontre des intérêts de l’État; •     acted within the scope of their duties or course of employment with respect to the acts or omissions giving rise to the request. •     a agi dans l’exercice de ses fonctions ou dans le cadre de son emploi, relativement à l’acte ou à l’omission qui a donné lieu à la demande. 6.1.6 Legal assistance: Deciding whether to approve legal assistance requests of Crown servants who meet the three basic eligibility criteria in the following situations: 6.1.6 Services juridiques: décider d’approuver ou non la demande de services juridiques d’un fonctionnaire de l’État qui satisfait aux trois critères d’admissibilité de base: •     when they are sued or threatened with a suit; •     lorsqu’il est poursuivi en justice ou menacé de poursuite; •     when they are charged or likely to be charged with an offence; •     lorsqu’il est inculpé ou susceptible d’être inculpé; •     when they are named in a legal action or under threat of being named in a legal action; or •     lorsqu’il est nommé ou susceptible d’être nommé dans une poursuite; •     when they are faced with serious personal liability before any court, tribunal or other judicial body. •     lorsqu’il fait face à une responsabilité personnelle grave devant tout tribunal, cour ou autre organisme judiciaire. 6.1.9 Parliamentary proceedings, commissions of inquiry, inquests or other similar proceedings: Deciding whether to approve requests for legal assistance where a Crown servant is requested or compelled to appear in connection with a parliamentary proceeding, a commission of inquiry, an inquest or other similar proceedings, provided two qualifying criteria are met: 6.1.9 Procédures parlementaires, commissions d’enquête, enquêtes et autres instances similaires: décider d’approuver ou non la demande de services juridiques dans le cas où le fonctionnaire de l’État est convoqué ou contraint de se présenter dans le cadre d’une procédure parlementaire, d’une commission d’enquête, d’une enquête ou d’une autre instance similaire, à condition qu’il satisfasse aux deux critères d’admissibilité suivants: •          that it is in the public interest to have the Crown servant appear; and •          il est dans l’intérêt public que le fonctionnaire de l’État se présente; •          that the matter concerns events where the Crown servant was acting within the scope of his or her duties, or in the course of employment. l’affaire concerne des événements où le fonctionnaire de l’État exerçait ses fonctions ou agissait dans le cadre de son emploi. ...

Article 2.2 of this agreement provides that: The Subscription Price shall be paid and satisfied by [the limited partnership]: (a)   transferring to [Devonian] on the Closing Date all Permits that have been issued to it on or prior to the Closing Date and all Applications that are then outstanding but in respect of which Permits have not yet been issued as of the Closing Date; and (b)   performing and/or providing, or at the expense of the [limited partnership] engaging geologists, engineers, surveyors, lawyers, accountants and other service providers to perform and/or provide, all engineering, geological and/or other work, studies, reports, surveys, information and other services reasonably necessary or desirable in connection with the preparation and/or filing of the Applications or otherwise necessary or desirable to obtain the Permits and all other services reasonably necessary or desirable in connection with the incorporation and organization of [Devonian] and/or the administration of the business and affairs of [Devonian] pending the Closing Date, all of which Applications and Permits and the benefit of all of which services are hereafter referred to collectively as the “ Assets ” or the “ Purchased Assets ”, it being acknowledged and agreed to by the parties that the value of the said Purchased Assets is not less than the Subscription Price. ... Without limiting the generality of the foregoing, the Partners acknowledge and agree that: (a)   the Applications were made by the General Partner on behalf of and for the benefit of the Partnership and the General Partner shall hold, and hereby acknowledges and declares that it does hold, the Applications and all rights and interest therein or to be derived therefrom for the benefit of and as trustee and agent for the Partnership (subject however to the provisions of the Subscription and Roll-over Agreement); (b)   the General Partner is entitled to be reimbursed for all costs and expenses incurred by it in connection with the Applications or otherwise relating to the lands covered by such Applications in priority to any distributions of Income or Net Cash Receipts to the Limited Partners hereunder; and (c)   the General Partner does not and shall not have or retain any rights or interests in or derived from the Applications in its own corporate capacity other than the right to be reimbursed for the costs and expenses as aforesaid. ...