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As the Appellant argues, the subcomponent (ii) amount does not exist if there were no segregated funds. [89]     I do acknowledge a more significant connection between the subcomponent (ii) amount and the guarantee accounted for as the subcomponent (iii) amount. [20] [90]     While it is clear that the connection is not such as would detract from the conclusion that the subcomponent (ii) amount is an amount calculated with reference to a liability in respect of segregated funds, the question might still be asked as to whether the negative reserve amount, calculated with reference to a liability in respect of segregated funds, is also a liability in the respect of the guarantee. ... Considering the connection, I am still of the view that it would not be correct to say that the negative reserve amount is a liability in respect of the guarantee. ... These are connections on which it seems the Respondent relies. [21] [1998] F.C.J. 1033 [22] [2000] F.C.J. ...

In connection with his work at the Centre d'accueil and his doctoral studies, the appellant felt the need to better coordinate inter-institutional services within the health and social services network. ... The latter was established on November 17, 1987 by Michel Picotte and Stéphane Gagnon (Exhibit I-2, Tab 64), two key people named on the offering memorandum issued in connection with the PC-DOS project (Exhibit I-2, Tab 34, page 7). ... Papion testified in court that the expenditures that were claimed as having been made in 1986 in connection with the PC-DOS project were clearly unreasonable. ...

In this connection, it is to be noted that in many provisions of the Income Tax Act the deduction or non-deduction of a particular type of expense is stated in terms of both an expense made or incurred. ... Counsel concludes that the evidence disclosed in the present case does not tend to demonstrate that the bonus had any connection with the earning of income. [58] Counsel for the respondent also referred to the decision rendered in The Queen v. ... I agree with the respondent that the evidence did not demonstrate that the bonus had any connection with the earning of income. [69] I therefore conclude that the appellant has not shown on the balance of probabilities that the $1,400,000 bonus was an expense incurred for the purpose of earning income within the meaning of paragraph 18(1)(a) of the Act. ...

Its business was the conduct of research, particularly in connection with construction. ... Shead"s connections with Anaquan and Mr. McLellan, Anaquan"s first president, go back to 1984 when he incorporated the company and subsequently acted as an adviser to it. ... Shead"s long standing connection with Anaquan and Mr. McLellan. Indeed, Mr. ...

In part because the statute does not specify that members of the CITT need have any particular technical qualifications, Mattel Canada argues that the appropriate standard of review of the CITT’s decision in the present appeal should be reasonableness.   30           In this connection, Wilson J. observed in National Corn Growers Assn. v. ... Minister of National Revenue (Customs and Excise) (1997), 131 F.T.R. 102, MacKay J. concluded that royalties may be a condition of sale as long as there is “some connection between the fee in question and the goods purchased” (p. 108).  ... The Deputy Minister used similar language like “true connection”, “effective control”, “practical” and “logical” to describe the manner in which the royalties that Mattel Canada paid to Licensor X could constitute “a condition of the sale of the goods for export to Canada” as between Mattel U.S. and Mattel Canada.   64           The words “condition of the sale” as they appear in s. 48(5)   (a)(iv) are clear and unambiguous.  ...

Stewards are persons who have a commercial connection with the designated waste or with a product from which the designated waste is derived.- The stewards are required to pay fees to the industry funding organization. ... Once a person is found to have, under the MHS Waste Program Agreement, the required commercial connection with the MHS Waste, the person is deemed to be an MHSW Steward. ... So there’s a connection between the volumes they produce, generate and sell, and what they pay. [38] [115]   In short, the fee is an estimate of the costs the Appellant incurred in collecting and recycling the MHS Waste with which the steward has a commercial connection under the WD Act. ...

In particular, Lazard Frères, being a French firm, had the necessary connections and experience to assist with issues arising in France and with the analysis of French capital markets: see Reasons at paras. 12 and 21. [10]   On July 2, 2003, the Alcan board of directors approved a purchase offer proposal for Pechiney’s share capital. ... It noted that no one who provided services in connection with the financial information was called to testify. ... Alcan argued, on the basis of paragraphs 34 to 38 of ITA Travel, that “commission” meant an amount calculated by reference to a percentage of the price of a product or a percentage of the profit earned by a principal in connection with a transaction. ...

Robinson had mentioned his age as being a factor there was no connection found between his age and his ability to pay his taxes. ... The Decision Maker indicated he had reviewed the cases and found no connection between the facts of those cases and Mr.  ... He claims that the non-filer NOA was the cause of the penalty and interest charged to him and it was an error on the part of CRA to issue it. (1)   The Alleged Causal Connections [91]   When asked at the hearing to explain to the Court the causal connection between the issuance of the non-filer NOA and the claim that Mr.  ...

The Third Party Respondents Distributel Communications Limited [Distributel] and Cogeco Connexion Inc. ... In doing so the user will only rely on the ISP to facilitate the connection to the VPN; all other Internet connections are initiated through the VPN thereby avoiding any blocking undertaken by the ISP. ... DBA EASTLINK COGECO CONNEXION INC. DISTRIBUTEL COMMUNICATIONS LIMITED FIDO SOLUTIONS INC. ...

It used to claim refundable ITCs in connection with its SR&ED activities, but ceased doing so when it became public in 2004. [10]   In 2005, Public CO2 had the following structure. ... It had its own bank account, its accounting, its financial statements, and so on and so forth. [24]   If there was any connection between the appellant and Public CO2, it was that of a partnership stemming from the research contract and from the fact that it retained intellectual property. ... In connection with these expenses and under subsections 127(9), 127(10.1) and 127.1(1) of the ITA, the appellant claimed an investment tax credit (hereafter “ITC”) of $291,055 and a refundable ITC of $280,112. ...