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Required connection between move and employment/business/education 4.7 To satisfy the condition described in ¶ 4.3(a) or ¶ 4.4 (a), there must be a connection between the individual’s move and one of the following activities: carrying on a business or being employed at a location in Canada or attending an educational institution. Whether such a connection exists in a given situation can only be determined by examining the circumstances surrounding the move. 4.8 The required connection does not exist when an individual moves solely for personal reasons. 4.9 For an employee or self-employed individual, the connection can exist, for example, in the following situations: an employee moves due to a transfer to another establishment of the employer; or a self-employed individual moves for business reasons, such as needing to be closer to a possible market or resources needed for the business (for example natural resources, raw materials, or specialized equipment). Generally, the connection can exist even if there is a delay between the move and the time the business or employment activity at the new work location is undertaken. 4.10 For a student, the connection may exist and an eligible relocation may occur even if a student moves to attend an educational institution as well as to be employed. ...

Required connection between move and employment/business/education 4.7 To satisfy the condition described in ¶ 4.3(a) or ¶ 4.4 (a), there must be a connection between the individual’s move and one of the following activities: carrying on a business or being employed at a location in Canada or attending an educational institution. Whether such a connection exists in a given situation can only be determined by examining the circumstances surrounding the move. 4.8 The required connection does not exist when an individual moves solely for personal reasons. 4.9 For an employee or self-employed individual, the connection can exist, for example, in the following situations: an employee moves due to a transfer to another establishment of the employer; or a self-employed individual moves for business reasons, such as needing to be closer to a possible market or resources needed for the business (for example natural resources, raw materials, or specialized equipment). Generally, the connection can exist even if there is a delay between the move and the time the business or employment activity at the new work location is undertaken. 4.10 For a student, the connection may exist and an eligible relocation may occur even if a student moves to attend an educational institution as well as to be employed. ...

S4-F8-C1- Business Investment Losses-- summary under Subparagraph 40(2)(g)(ii) Summary Under Tax Topics- Income Tax Act- Section 40- Subsection 40(2)- Paragraph 40(2)(g)- Subparagraph 40(2)(g)(ii) connection between loan and income-producing purpose 1.46... ... The burden of demonstrating a sufficient connection between the taxpayer’s loan to (or the taxpayer’s guarantee of the debts of) the debtor and the potential for income will be much higher in situations where the taxpayer is not a direct shareholder of the debtor.... 1.48 For an example of a case where the taxpayer did not own shares directly in the debtor corporation but a sufficient connection was shown to exist for the exception described in ¶ 1.44(a) to apply, see Alessandro v The Queen, 2007 TCC 411 &d1=&d2=&su=0"> 2007 TCC 411; 2007 DTC 1373 (TCC). For an example of a case where the connection was found to be too remote, see Service v The Queen, 2004 TCC 592 &d1=&d2=&su=0"> 2004 TCC 592, 2004 DTC 3317, which was affirmed by the Federal Court of Appeal in Service v Canada 2005 FCA 163 "> 2005 FCA 163, 2005 DTC 5281). ...

S3-F9-C1- Lottery Winnings, Miscellaneous Receipts, and Income (and Losses) from Crime-- summary under Paragraph 40(2)(f) Summary Under Tax Topics- Income Tax Act- Section 40- Subsection 40(2)- Paragraph 40(2)(f) Lottery Schemes 1.17 Paragraph 40(2)(f) specifies that no taxable capital gain or allowable capital loss results from the disposition of a chance to win or a right to receive an amount as a prize in connection with a lottery scheme. ... Pool system betting 1.19 Paragraph 40(2)(f) also provides that no taxable capital gains or allowable capital losses arise from the disposition of a chance to win a bet or a right to receive an amount as winnings on a bet in connection with a pool system of betting. ...

S4-F2-C1- Deductibility of Fines and Penalties-- summary under Subsection 10(1) Summary Under Tax Topics- Income Tax Act- Section 10- Subsection 10(1) 1.20...If a fine or penalty is incurred in connection with the acquisition or production of inventory, the fine or penalty is included in the cost of inventory. ...

S4-F2-C1- Deductibility of Fines and Penalties-- summary under A Summary Under Tax Topics- Income Tax Act- Section 13- Subsection 13(21)- Undepreciated Capital Cost- A 1.20 If a fine or penalty is incurred in connection with the acquisition of an asset for which capital cost allowance (CCA) may be claimed, the fine or penalty may be included in the capital cost of that asset (or the CCA class to which the asset belongs). ...

S4-F2-C1- Deductibility of Fines and Penalties-- summary under Cumulative Eligible Capital Summary Under Tax Topics- Income Tax Act- Section 14- Subsection 14(5)- Cumulative Eligible Capital 1.21 If a fine or penalty is incurred in connection with the acquisition of an eligible capital property, the fine or penalty is an eligible capital expenditure provided all the other tests in the subsection 14(5) definition of eligible capital expenditure are met. ...

S4-F2-C1- Deductibility of Fines and Penalties-- summary under Eligible Capital Expenditure Summary Under Tax Topics- Income Tax Act- Section 14- Subsection 14(5)- Eligible Capital Expenditure 1.21 If a fine or penalty is incurred in connection with the acquisition of an eligible capital property, the fine or penalty is an eligible capital expenditure provided all the other tests in the subsection 14(5) definition of eligible capital expenditure are met. ...

S4-F2-C1- Deductibility of Fines and Penalties-- summary under Subparagraph 40(1)(a)(i) Summary Under Tax Topics- Income Tax Act- Section 40- Subsection 40(1)- Paragraph 40(1)(a)- Subparagraph 40(1)(a)(i) 1.22 If a fine or penalty (such as a mortgage prepayment penalty) is incurred in connection with the disposition of a capital property, the fine or penalty is taken into account under subsection 40(1) for purposes of calculating any gain or loss on that disposition. ...

In this context, the words in respect of have been held by the courts to imply a connection between the loss of employment and the subsequent receipt, where the primary purpose of the payment is to compensate for the loss of employment. Two questions set out by the courts to determine whether such a connection exists for purposes of a retiring allowance are as follows: Question 1 – But for the loss of employment would the amount have been received? ...