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The Queen, 95 DTC 5058, [1995] 1 CTC 203 (FCTD)-- summary under Section 231.2 Summary Under Tax Topics- Income Tax Act- Section 231.2 The IRS requested assistance from Revenue Canada in connection with a criminal investigation of a client ("Lieberman") of the applicant, who was a BC barrister. ... Income Tax Convention notwithstanding that there was only oral disclosure that the information was requested by the U.S. tax authorities in connection with an income tax investigation of Lieberman pursuant to Article XXVII. ...

., 92 DTC 6123, [1992] 1 CTC 183 (FCA)-- summary under Paragraph (a) Summary Under Tax Topics- Income Tax Act- Section 66.1- Subsection 66.1(6)- Canadian exploration expense- Paragraph (a) no connection betweeen lease payments and exploration In finding that annual rental or other payments to provincial governments made for the purpose of keeping leases or licences to subsurface oil and gas rights current were not CEE, Hugessen J.A. stated (p. 6128): "... ... [T]here would have to be at least some connection between that expense and the work actually done on the ground... ...

In addition "in order for the taxpayer to be permitted [the deduction]...the person to whom the money is paid for the purpose of making the service connections must be the person who supplies the electricity, gas, telephone service, water or sewers for the supply of which connections are made. ...

MNR, 90 DTC 1050, [1990] 1 CTC 2141 (TCC)-- summary under Section 62 Summary Under Tax Topics- Income Tax Act- Section 62 In 1981 the taxpayer deducted expenses in moving from the family home in Montreal to a temporary residence in Edmonton and in 1983 he deducted further expenses incurred in connection with moving from Edmonton to Victoria to take up a new teaching position. It was held that he could not deduct in 1984 expenses incurred in connection with moving in 1984 his family's effects from the Montreal home to Victoria. ...

Although the purchase commissions were found to be dependent on sales of goods by manufacturers to Hasbro that were described in s. 212(1)(d)(iii)(B), by the same token they were excluded by the postamble: the phrase "in connection with" was clearly broader in its scope than the phrase "dependent on". Furthermore, at least some portion of the payments made was made for services in connection with the negotiation of a contract, and accordingly all the payment were exempt from withholding tax as the Minister had not designated which portion should be taxable under s. 212(1)(d)(iii). ...

Canada, 2009 DTC 5940, 2008 FCA 419-- summary under Cumulative Eligible Capital Summary Under Tax Topics- Income Tax Act- Section 14- Subsection 14(5)- Cumulative Eligible Capital A lump sum received by the taxpayer in consideration for the cancellation of a non-competition agreement that it previously had received in connection with an acquisition of a business as a going concern represented proceeds of "disposition" on general principles given that the agreement was extinguished, and also was received on capital account given that (from the perspective of the taxpayer) an acquisition of a non-competition agreement in connection with its business would have been on capital account. ...

Attorney- General of Canada and Bassermann (1994), 114 DLR (4th) 104 (FCA)-- summary under Subsection 241(3) Summary Under Tax Topics- Income Tax Act- Section 241- Subsection 241(3) Before going on to confirm the decision of the Tax Court Judge to allow the appeal of the respondent from an assessment for UIC premiums in relation to temporarial secretary help obtained by him because of a failure of Revenue Canada to produce the income tax returns of the secretary's, Mohoney J.A. noted that amendments to s. 241 would not have prevented what had happened here (pp. 107- 108): "The prohibition of s-s.(2) against disclosure of an income tax return 'in connection with any legal proceedings' is subject to the exception of s-s.(3)(b) as to proceedings relating to the administration or enforcement of, among others, the Unemployment Insurance Act... The order made here can still be made without a taxpayer knowing that his or her return is required to be disclosed in its entirety to a business connection." ...

La Reine, 2005 DTC 514, 2005 TCC 66, aff'd 2008 DTC 6100, 2006 FCA 35-- summary under Subparagraph 115(1)(a)(ii) Summary Under Tax Topics- Income Tax Act- Section 115- Subsection 115(1)- Paragraph 115(1)(a)- Subparagraph 115(1)(a)(ii) sales in Canada were indivisible whole The taxpayer was found to be carrying on business in Canada on the basis that through a Canadian mandatory it offered for sale, in Canada, Costa Rican plantation lots and solicited orders for services to be provided by it in connection with the sold lots, with each investor paying an overall amount in connection with the transactions which constituted an "indivisible whole" (p. 519). ...

La Reine, 2005 DTC 514, 2005 TCC 66, aff'd 2008 DTC 6100, 2006 FCA 35-- summary under Paragraph 253(b) Summary Under Tax Topics- Income Tax Act- Section 253- Paragraph 253(b) The taxpayer was found to be carrying on business in Canada on the basis that through a Canadian mandatary it offered for sale, in Canada, Costa Rican plantation lots and solicited orders for services to be provided by it in connection with the sold lots, with each investor paying an overall amount in connection with the transactions which constituted an "indivisible whole" (p. 519). ...

The Queen, 2005 TCC 493 (Informal Procedure)-- summary under Subsection 169(1) Summary Under Tax Topics- Excise Tax Act- Section 169- Subsection 169(1) fees incurred in connection with parent’s issuing units, with proceeds used in the registrant’s business, were eligible The appellant, which became a wholly-owned subsidiary of a new income fund (the “Fund”), incurred $78,000 in fees directly to an investment dealer, law firms and a printing company in connection with the IPO of the Fund. ...