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In that finding this sum was an income receipt Woods J. noted that the claim of the taxpayer (as evidenced by its brief and memorandum filed in connection with the infringement litigation) was for lost profits rather than damage to its goodwill, that the action of the competitor did not in fact damage the taxpayer's patents in the sense of any diminution in the taxpayer's statutory rights under the Patent Act and that the fact that the parties came to a compromise and settled for an amount that bore no relationship to the profits lost by the taxpayer did not change the nature of the interest of the taxpayer that was settled. ...

…[T]he expenditures should be viewed as ordinary expenditures incurred in connection with the day-to-day management of the rental property. ...

La Reine, 2012 DTC 1076 [at at 2856], 2011 TCC 438 (Informal Procedure)-- summary under Subsection 5(1) Summary Under Tax Topics- Income Tax Act- Section 5- Subsection 5(1) Archambault J. found that "bursary" amounts that the taxpayer received from the University of Laval in connection with his postdoctoral fellowship at that university were employment income rather than amounts described under s. 56(1)(n) (scholarship, bursary, fellowship or prize for achievement), because his work was in the nature of "employment" under Quebec civil law. ...

The Queen, 2011 DTC 1163 [at at 873], 2011 TCC 213-- summary under Legal and other Professional Fees Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Legal and other Professional Fees improved tax efficiency was enduring (3 year) benefit The taxpayer incurred legal and accounting fees in 1997 and 1998 of approximately $1.9 million in connection with a complicated reorganization of the manner in which it financed its investment in its US subsidiaries. ...

He also noted that the words "directly" and "in connection with" mean "activities which, first, are connected with manufacturing and processing operations in Canada but are not an integral part of the actual manufacturing and processing process" (p. 2258). ...

Humber (also involving a CNA-Q instructor) was distinguished on the basis that there the connection between CNA's activities and oil exploitation had not been adequately established. ...

The Queen, 2012 DTC 1190 [at at 3488], 2012 TCC 212 (Informal Procedure)-- summary under Paragraph 56(1)(n) Summary Under Tax Topics- Income Tax Act- Section 56- Subsection 56(1)- Paragraph 56(1)(n) dominant character of payments made to post-doctoral fellow was compensation for research work The taxpayer sought an exemption under s. 56(1)(n) in respect of income from the Ontario Health Research Institute ("OHRI") in connection with a postdoctoral fellowship at the University of Ottawa. ...

In finding that there have been no misrepresentation by the taxpayer in connection with not including these amounts in his income, Mr. ...

The taxpayer claimed input tax credits on expenses relating to the operation of a private jet, which were incurred primarily in connection with Mr. ...

Although the Canadian agents issued "conditional receipts" in Canada providing temporary insurance, the policies which the taxpayer ultimately issued in the United States following the completion of the underwriting process stated that the final contract and the application (in connection with which the conditional receipts were issued) were one entire contract, and it was clear that those contracts were concluded in the United States rather than in Canada. ...