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The Queen, 2002 DTC 2185, 2002 CanLII 47015 (TCC)-- summary under Paragraph 20(1)(e) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(e) The taxpayer paid a fee to a financial advisor, calculated as 0.7% of the market value of its equity and of the amount of its long-term debt net of working capital, in consideration for advice provided in connection with considering alternatives to maximize shareholders' value, with an emphasis on merger possibilities. ...

" In light of the fact that the taxpayers were members of two Amway networks which had their bases in North Carolina and Maine, the expenses they incurred in attending the meetings in the U.S. were found to have been incurred in connection with their business and in a location reasonably consistent with the territorial scope of the two organizations. ...

The Queen, 95 DTC 164 (TCC), briefly aff'd 97 DTC 5012 (FCA)-- 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 Legal and accounting fees paid by the taxpayer in connection with the preparation of management circulars, which were sent to shareholders in response to three take-over bids, were fully deductible. ...

MNR, 91 DTC 1286 (TCC)-- summary under Paragraph 212(4)(b) Summary Under Tax Topics- Income Tax Act- Section 212- Subsection 212(4)- Paragraph 212(4)(b) Beaubier J. affirmed the disallowance by the Minister of all but $100,000 per year of amounts paid by a Canadian subsidiary to its U.S. parent which allegedly were reimbursements of expenses incurred by the parent in connection with litigation involving the Canadian subsidiary, and for accounting, administrative and sales services, and for overheads, of the U.S. parent. ...

Expense- Start-Up and Close-Down Expenditures The taxpayer, which had a 25% interest in an oil field under the North Sea, was not permitted to deduct a provision for the estimated costs to be incurred at a future date, on completion of production, in order to: restore to their original condition rigs and tankers that it had leased and adapted for use in connection with extracting or transporting the oil; removing a manifold, loading lines and buoy from the area; and capping wells and removing well heads. ...

The Queen, 2006 DTC 3431, 2006 TCC 347, aff'd supra 2008 DTC 6017, 2007 FCA 370-- summary under Paragraph 6(1)(a) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a) appreciation in warrants allocated to employees on capital account The taxpayer's employer ("Canaccord"- a broker dealer) was issued broker compensation warrants in connection with an equity treasury financing by a Canaccord client, and Canaccord allocated a portion of those warrants to the taxpayer as compensation for his employment services. ...

.)-- summary under Solicitor-Client Privilege Summary Under Tax Topics- General Concepts- Solicitor-Client Privilege The TD Bank sued a corporation for negligent misrepresentation with respect to a comfort letter received in connection with a $40.5 million loan to the corporation's subsidiary. ...

There was evidence that the taxpayer's farming operations resulted in connections that enhanced the profitability of his law practice and that "his day to day life involved both, and the contacts he made in farming became valuable to his law practice". ...

(a) of the definition of "commercial activity" – nor was there any evidence that the sale was connected to any existing commercial activity of NM (including any connection which could engage ss. 141.1(1)(a) and (2)(a).) ...

A.G. of Canada, 2015 QCCA 837-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission thin cap issues were not considered at time of paying a dividend The appellant, which was a wholly-owned Ontario subsidiary of a Quebec corporation ("CTI"), paid a $136 million dividend to CTI in connection with a "Quebec shuffle" transaction. ...