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The Queen, 2008 DTC 4982, 2007 TCC 647, aff'd, 2009 DTC 5940, 2008 FCA 419-- summary under Compensation Payments Summary Under Tax Topics- Income Tax Act- Section 9- Compensation Payments negotiated lump sum received for cancellation of non-compete was for diminution in value of goodwill A lump-sum payment received by the taxpayer in consideration for the cancellation of a non-compete covenant that had previously been given to it in connection with its acquisition of a business was a capital receipt given that the lump sum compensated it for a diminution in the market value of the goodwill that had been so acquired by it. ...

La Reine, 2007 DTC 1534, 2007 TCC 461 (Informal Procedure)-- summary under Disposition Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Disposition legal expenses incurred re cancellation of purchase may be loss from disposition Paris J. indicated, in obiter dicta at para. 22, that legal expenses incurred by the taxpayer in connection with her cancellation of a contract to purchase a building might have given rise to a capital loss on the basis that "the expenses may have been incurred as part of a disposition of the Appellant's right to purchase the building, and the disposition of that right may constitute a disposition of property within the meaning of section 38 and of the definition of 'property' set out in subsection 248(1) of the Act". ...

The Queen, 2005 DTC 1151, 2005 TCC 492, aff'd 2006 DTC 6447, 2006 FCA 216-- summary under Subsection 2(1) Summary Under Tax Topics- Income Tax Act- Section 2- Subsection 2(1) An Air Canada pilot who took up residence in the Bahamas continued to be resident in Canada given that his work routine (which was centred on Pearson Airport) and family connections caused him to spend more than one-third of his time in Canada (during which time he would stay at his mother-in-law's apartment in Canada) and that he used a Canadian bank account for most of his banking. ...

The Queen, 2003 DTC 420, 2003 TCC 160 (TCC) (Informal Procedure)-- summary under Subparagraph 6(1)(b)(vii.1) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(b)- Subparagraph 6(1)(b)(vii.1) travel between home office and school board meetings were in course of employment Travel allowances (calculated on a per-kilometre basis) received by the taxpayers in respect of their mandatory attendance at School Board meetings in connection with their duties of employment were not includable in their income given that they maintained offices in their homes, so that when they went from their home offices to the School Board premises they were engaged in carrying out their duties of a School Board member. ...

The Queen, 2021 TCC 92 (Informal Procedure)-- summary under Subsection 118.01(2) Summary Under Tax Topics- Income Tax Act- Section 118.01- Subsection 118.01(2) the non-inclusion of surrogate parent expenses under s. 118.01 did not violate s. 15 equality rights The taxpayer unsuccessfully claimed that the exclusion from the scope of the adoption tax credit (“AETC”) under s. 118.01 of various expenses he incurred in connection with having a surrogate mother bearing a child derived from an embryo from him and his wife infringed his equality rights under s. 15 of the Charter. ...

.$2.9 billion made to settle actions against it in connection with the Enron bankruptcy included whether the settlement amount should have been reimbursed to it by subsidiaries whose conduct may have been the primary basis for the actions. ... Litigation privilege was not available for various documents prepared in connection with the Enron litigation given that (para. 178): the parties are not the same as the Enron litigation, and the cause of action is completely different. ...

. … [T]he broad wording of paragraph 6(1)(a) requires only the slightest connection between the benefit and employment. That does not preclude benefits received where, in addition to the required connection between benefit and employment, there also may have been considerations extraneous to employment. ...

Miller J. allowed the taxpayer to deduct 50% of approximately $24,000 of business losses incurred in connection with a pyramid sales organization called Advantage Conferences. ...

The Minister limited the taxpayer's deductions in connection with the note portion to the amount of licensing revenues ultimately received. ...

The Minister limited the taxpayer's deductions in connection with the note portion to the amount of licensing revenues ultimately received. ...