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The payment could not be characterized as a reimbursement for actual losses incurred by him in connection with the transfer. ...

The Court affirmed the finding of the trial judge that the maintenance of a small office on the reserve that was used principally for the purpose of distributing cheques to the Indian employees of the company, and the fact that the earning of remuneration or profits from the company had a general economic benefit for the reserve, were not sufficient connections to the reserve to establish exemption. ...

The payments were capital outlays since they established a permanent physical connection between the taxpayer's plant and the Anglo-Canadian plant, that enabled the taxpayer's plant to be readily and easily supplied with steam and pulp, and thereby increased the value and desirability of the taxpayer's plant. ...

Canada, 2003 FCA 446-- summary under Subsection 169(1) Summary Under Tax Topics- Excise Tax Act- Section 169- Subsection 169(1) legal costs of shareholder too remote GST on legal services supplied to the applicant to enable him and his company to obtain damages from a bank for wrongfully calling in a loan to the company, thereby forcing it out of business, was not eligible for an input tax credit given that the applicant had not established a connection, direct or indirect, between his purchase of the legal services and any ongoing supply of taxable services. ...

., 98 DTC 6604, [1999] 2 CTC 178 (FCA)-- summary under Paragraph 20(1)(c) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c) guarantee re personal loan The taxpayer's husband borrowed $20,000, on the security of a mortgage on a rental property, to pay legal costs in connection with a civil suit unrelated to the rental property, with the taxpayer guaranteeing her husband's loan. ...

Linden J.A. noted (at p. 5608) that the phrases "because of" or "as a consequence of" in s. 80.4(1) required "a strong causal connection" and went on to find that because the employees (who already had Calgary homes) obtained their new form of mortgage financing largely independently of employer involvement, it was reasonable to consider that the new mortgage debt was incurred "in order to obtain ownership of a house, not... 'as a consequence of'... employment". ...

., 89 DTC 5404, [1989] 2 CTC 246 (FCA)-- summary under Personality Summary Under Tax Topics- General Concepts- Personality The taxpayer ("MerBan") in connection with a leveraged share acquisition arranged for borrowings to be made to two special purpose subsidiaries in order to limit its liability and to facilitate the use of an income debenture. ...

., 89 DTC 5404, [1989] 2 CTC 246 (FCA)-- summary under Separate Existence Summary Under Tax Topics- General Concepts- Separate Existence The taxpayer ("MerBan") in connection with a leveraged share acquisition arranged for borrowings to be made to two special purpose subsidiaries in order to limit its liability and to facilitate the use of an income debenture. ...

He used a room in his apartment for preparing weekly invoices (which he sent to his placement agency), updating his resumé, typing letters to prospective employers, and making calculations and preparing sketches in connection with the current engagement. ...

Canada (National Revenue), 2021 FCA 101-- summary under Stare Decisis Summary Under Tax Topics- General Concepts- Stare Decisis stare decisis does not apply horizontally In connection with finding that there is no reversible error of a Federal Court judge in not following a prior decision of a colleague, Pelletier JA stated (at paras. 30-31): … Judicial comity is a doctrine which seeks to promote uniformity and predictability in the law. ...