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In this connection he mentioned in particular the Métro name, the prestige connected with this banner and the advertising done by Métro. ... Brunetta noted that Métro secured two important benefits: a long-term connection with a food merchant and a better concentration of purchasing of its products. ... That penalty and the ratios required however have no connection with the volume discount or other discounts currently in use. — Right of first refusal over the sale of the business or shares of the company, right to a possible lease of the premises of the food market. ...

However, it is our opinion that Mersey Seafoods Limited has no manufacturing or processing profits, in connection with the “Mersey Viking” since the activities started out aboard the vessel were not performed by employees of the company but rather by self-employed individuals. ... If the activity did not occur in Canada it is not a “qualified activity”, which is defined in regulation 5202 as one “... performed in Canada in connection with manufacturing or processing...”. ... For the purposes of this Act, “Canada” is hereby declared to include and to have always included (a) the sea bed and subsoil of the submarine areas adjacent to the coasts of Canada in respect of which the Government of Canada or of a province grants a right, licence or privilege to explore for, drill for or take any minerals, petroleum, natural gas or any related hydrocarbons; and (b) the seas and airspace above the submarine areas referred to in paragraph (a) in respect of any activities carried on in connection with the exploration for or exploitation of the minerals, petroleum, natural gas or hydrocarbons referred to in that paragraph. ...

The proper characterization of a commercial, contractual, business, work, or family relationship for purposes of the application of the federal Act will generally need to be determined in accordance with, or least after considering, the provincial law applicable to the relationship or transactions. [9]              This limitation is compounded by the fact that Canada is a bijural common-law/civil law country and, in this case, the Appellant has some direct or indirect connections to the province of Quebec. [10]         It is not clear that there is a federal meaning of the concept of debt, and neither of the parties asked the Court to adopt one. ... It follows that the availability of the manufacturing and processing incentives at issue must be restricted to property utilized in the supply of goods for sale and not extended to property primarily utilized in the supply of goods through contracts for work and materials. 30 It is perhaps true, as Will-Kare submitted and as noted in Halliburton, supra, at p. 5338, that the use of sale of goods law distinctions sometimes yields the anomalous result that the provision of services in connection with manufactured and processed goods will disqualify property that would, but for the services, qualify for the incentives. ... Principal/Principal Amount: [91]         It appears from a review of the Act that, with limited exceptions, the words “principal amount” and “principal” are only ever used in connection with circumstances involving debts. [92]         As mentioned above, paragraph 53(2)(c) and subsection 248(34) refer to the “principal amount” of “indebtedness”. ...

In the interim, Motiuk stated she received requests for information and applications for social insurance numbers or UI benefits which, although some of them might have been farm labourers, had no connection to her regular duties or to the function of the AES office. ... The necessary computer program was operated by the Regional Informatics Branch- a creation of the federal government- and AES staff received training on that system in Edmonton and all expenses in connection with attendance for that purpose were paid, even if a local operating budget had to be amended and more money supplied by HRDC in a forthcoming monthly cheque to cover those costs. ... This is particularly true when the person has no prior employment connection with the party who benefits from his services. ...

The matter of ties within the jurisdiction asserting residence and elsewhere runs the gamut of an individual's connections and commitments: property and investment, employment, family, business, cultural and social are examples, again not purporting to be exhaustive. ... There the             question is whether that person has become "ordinarily resident" in Canada; (c) cases where a Canadian resident leaves Canada and severs his           or her connection with this country so that he or she is not a     Canadian resident, and then reacquires ties here. ... This is shown by the various factors, which have already been related which indicated that he still had substantial connections to Canada. [115]        In essence counsel argued that on the totality of evidence, the Appellant's presence in the U.S. in the years in question was temporary and his ties to Canada, albeit not as deep-rooted as one would expect if somebody resided in Canada for 15 or 20 years, since he was a recent immigrant from Nigeria to Canada, indicate that his intention was to come back to Canada. [116]        There are a number of references in the evidence to correspondence between the Appellant and the C.C.R.A., where he expressly stated that he would be returning to Canada upon the conclusion of his program and at the end of the day he did return to Canada. ...

In connection with the matters described in subparagraphs (a) through (i), the Association has paid or incurred legal fees of approximately $1,500,000. 39. ... The cost of the annual education seminars is covered by a grant received from the Alberta Government. [4]           Neither party called any witnesses nor produced any further documents in evidence. [5]           Counsel for the appellants submitted the issue to be decided is as follows: Whether the amounts paid by the appellants to the Alberta Provincial Judges' Association are membership dues in an association of public servants the primary purpose of which is to promote the improvement of its members' conditions of employment or work pursuant to subparagraph 8(1)(i))iv) of the Act. [6]           Although pleaded- in the alternative- in each Notice of Appeal filed on behalf of each appellant, submission on the issue of deductibility of membership dues pursuant to paragraph 8(1)(b) of the Act- on the basis there was a connection between payment of Association dues and the establishment of a right to salary or wages owed to each appellant- and to all other judges of the Provincial Court of Alberta- was abandoned by counsel for the appellants. [7]      The relevant portions of subparagraph 8(1)(i)(iv) of the Act read as follows: 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:...    ... It would have been extremely difficult to consider the total amount of the membership fee and to somehow attribute an appropriate portion thereof directly to each member's pro rata cost of the global litigation which, inter alia, produced the salary reimbursement as opposed to allocations in respect of other Association activities, such as costs incurred in connection with conferences and meetings having other purposes. [40]     The assessment(s) of the Minister- as they apply to each appellant- are valid. ...

Without limiting the generality of the foregoing, the Assets include:               (i)         the Sites and Buildings;               (ii)        the Equipment;               (iii)       the Land Rights;               (iv)       the Current Assets;   (v)        the full benefit of the Contracts and all other contracts or commitments to which the Vendor or TransAlta Utilities Corporation or any of their Affiliates is entitled in connection with the Business including, without limiting the generality of the foregoing, all forward commitments of the Vendor or TransAlta Utilities Corporation or any of their Affiliates for supplies or materials entered into in the usual and ordinary course of Business whether or not there are any written contracts with respect thereto, but excluding, for clarity, contracts or commitments of a general nature that do not Primarily relate to the Business;   (vi)       the Warranties, if any;   (vii)      the Permits;   (viii)      computer software listed in Schedule 1.1(a);   (ix)       the goodwill of the Business including, without limiting the generality of the foregoing,   A.        ... It is the benefit and advantage of the good name, reputation, and connection of a business. ... The only real possible benefit was in connection with the one partner, Ontario Teachers Pension Plan Board, who may not have had to pay tax. ...

In addition, in later years the Conservatory Group provided mortgages to third-party purchasers in connection with its real estate business and invested large amounts of surplus funds in commercial paper ... It submits that the loan was made in connection with its overall profit-making scheme and was of a class of loan arrangement usually entered into by it. ... The exception carved out of these denial provisions permits the intercorporate dividend deduction in connection with term preferred shares acquired outside the “ordinary course of [the] business” carried on by the taxpayer ...

Krmpotic because of his connection to the numbered company. Precondition (3) has been met because the payment would have been for the benefit of Mrs. ...   [121]   Counsel argued that the Minister seemed to be thinking that the fact that these properties were written down somehow had a connection to the disposition of the property but the dates are completely different. ... Krmpotic was only in December of 2000 so there was no connection between the two. ...

Any claim for salary in connection with meetings away, other than the Confederation office or council must include a pay stub from the week in which the actual loss of salary occurred.     ... Expenses incurred in connection with activities held during a vacation period or on weekday programmed leave shall be reimbursed to the union member even if time is made up for.   ...   [57] In my opinion, this result is entirely in keeping with the situation of numerous volunteers who work for various charitable organizations and who render their services without being remunerated but are compensated for the expenses incurred in connection with the activities of these organizations, whether they be for profit or not. ...