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Canada, 2010 DTC 5101, 2010 FCA 159-- summary under Territorial Limits Summary Under Tax Topics- Statutory Interpretation- Territorial Limits no filing requirement if no connection with Canada Nöel, J.A. noted (at para. 23) that when s. 150(1) formerly simply provided that in the case of a corporation, a return shall be filed by a corporation for each taxation year, "with respect to non-resident corporations, the obligation to file could only extend to those that had some connection with Canada. To construe the provision as applying in the absence of any connection with Canada would give it a reach that could not have been intended. ...

The Queen, 97 DTC 342 (TCC)-- summary under Eligible Capital Expenditure Summary Under Tax Topics- Income Tax Act- Section 14- Subsection 14(5)- Eligible Capital Expenditure Professional fees incurred in connection with a share reorganization of the taxpayer in which its shareholders transferred their shares to a holding company were found not to be incurred in connection with any activities which formed part of the business by which the taxpayer earned income and were incurred in connection with its dealings with its own shareholders as shareholder. ...

This program was found not to be undertaken as part of her duties of employment or "in connection with" her duties of employment but, rather, was undertaken in connection with her profession. ... Words and Phrases in connection with ...

In finding that the taxpayer was not "controlled, directly or indirectly in any manner whatever, by one or more non-resident persons", Sexton J.A. noted (at para. 33) authorities suggesting "that a common connection must exist amongst the majority shareholders in order for them to compose a 'group of persons'," found that the quoted phrase was synonymous to control by a non-resident person or group of non-resident persons, that "'control' necessitates that there be a sufficient common connection between the several persons referred to in that definition in order for there to be control by those several persons" (para. 35) and that "the common connection might include, inter alia, a voting agreement, an agreement to act in concert, or business or family arrangements" (para. 36). Here, there was no evidence of any common connection among the non-resident shareholders. ...

The Queen, 97 DTC 342 (TCC)-- 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 Professional fees incurred in connection with a share reorganization of the taxpayer in which its shareholders transferred their shares to a holding company were found not to be incurred in connection with any activities which formed part of the business by which the taxpayer earned income and were incurred in connection with its dealings with its own shareholders as shareholder. ...

., 74 DTC 6180, [1974] CTC 209 (FCA)-- summary under Paragraph 20(1)(e) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(e) In connection with the interim construction of a building, the taxpayer agreed in 1962 to pay interest on the borrowed money at a rate of 9%, plus "additional interest", in each of the 25 years after 1964 in which it was profitable, of 1% of its gross rental income from the building. ... "What appears to me to be the test is whether the expense, in whatever taxation year it occurs, arose from the issuing or selling or borrowing... the words 'in the course of' in section 11(1)(cb) are not a reference to the time when the expenses are incurred but are used in the sense of 'in connection with' or 'incidental to' or 'arising from' and refer to the process of carrying out or the things which must be undertaken to carry out the issuing or selling or borrowing for or in connection with which the expenses are incurred" (p. 6183). ...

It appealed the denial of $5,039.77 in ITCs which it had claimed in its return for its three-month reporting period ending on March 31, 2011 in connection with various of its costs including fees paid in connection with the income fund conversion and in connection with news releases regarding its dividends. ...

“Stewards,” being persons who had a commercial connection with such waste, were statutorily responsible for paying fees to SO to reflect their reasonable share of the associated costs. ... Specifically, section 30 and subsections 31(1) and 34(6) of the WD Act provide that if a person has a commercial connection with designated waste or a product from which the designated waste is derived that person (i.e., a steward) must pay a portion of the Appellant’s cost of developing, implementing and operating a waste diversion program …. ... 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. … [O]nce the person becomes an MHSW Steward that person is required to pay the costs of collecting and recycling the designated waste. ...

Fogazzi, 93 DTC 5183, [1993] 2 CTC 319 (Ont CA)-- summary under Exempt Receipts/Business Summary Under Tax Topics- Income Tax Act- Section 9- Exempt Receipts/Business Funds received for investment by the accused from his Italian relatives were found to have been misappropriated by him in connection with a business given that the the funds were received by him in the normal course of the operation of his investment business and his dishonest act took place in connection with the operation of that business. ...

Fogazzi, 93 DTC 5183, [1993] 2 CTC 319 (Ont CA)-- summary under Expense Reimbursement Summary Under Tax Topics- Income Tax Act- Section 9- Expense Reimbursement Funds received for investment by the accused from his Italian relatives were found to have been misappropriated by him in connection with a business given that the the funds were received by him in the normal course of the operation of his investment business and his dishonest act took place in connection with the operation of that business. ...