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It was clear that the taxpayer’s wife, although having no formal connection to her husband’s employer, was seen with her husband, as it was put by Cattanach J. at page 479 (D.T.C. 5327), “as the selling unit” in the employer’s business. ... Although the first of these makes some reference to expenses incurred by an employee as well as by a spouse of an employee, it is of no relevance to the present case because Interpretation Bulletin IT-131R2 is expressly confined to “the deduction provided under subsection 20(10)...in respect of expenses incurred by the taxpayer in attending up to two conventions a year” in connection with a business or profession. ...

Clause 4 places a number of limits on the agent's authority: Limitation of Authority—The Agent agrees that he has no authority on behalf of the Company to: (a) Bind the Company in any way; (D) b) Interpret a contract of insurance so as to bind the Company; (C) Make, alter or discharge any contract; (d) Extend the time for payment of any premium; (e) e) Waive any forfeiture or grant any permit; (f) Incur any liability on behalf of the Company; (g) Make or allow the delivery of any policy not issued under a binding receipt, unless the applicant is at the time in good health and the first premium has been paid; (h) Collect a premium on any policy or a payment on any policy loan except as he may be authorized under this Agreement; (i) Give a receipt for any premium or payment except upon the printed form of receipt furnished by the Company for that purpose; (j) Vary any of the conditions contained in any printed form or receipt; (k) Institute or defend legal proceedings for any cause in connection with the transaction of the Company's business; (I) Publish any advertisement relating in any way to the business of the Company until a copy of same has been submitted to and approved by the Company. ... The term “business of insurance” is defined in subsection 2(1) of the Canadian and British Insurance Corporations Act, R.S.C. 1970, c. 1-15, as amended, as... the making of any contract of insurance and includes any act or acts of inducement to enter into a contract of insurance, and any act or acts relating to the performance thereof or the rendering of any service in connection therewith; The Non-Residents Insurance Act, 1967 (Bermuda) defines an “insurance business" to include “making out or executing policies of insurance”. ...

Subsection 44(2), as it read during the relevant period for purposes of the claims in this case, is as follows: 44.(2) Where goods have been purchased by Her Majesty in right of any province of Canada for any purpose other than (a) resale; (b) use by any board, commission, railway, public utility, university, manufactory, company or agency owned, controlled or operated by the government of the province or under the authority of the legislature or the lieutenant governor in council; or (c) use by Her Majesty or by Her agents or servants in connection with the manufacture or production of goods or use for other commercial or mercantile purposes; a refund of taxes paid under Part III, IV or V may be granted to Her Majesty or to the manufacturer, producer, wholesaler, jobber or other dealer as the case may require. ... All materials provided by the Contractor in connection with the work shall become, from the time of their being so provided until the final acceptance of the work, the property of the Minister for the purposes of said works, and the same shall on no account be taken away or used or dispensed with, except for the purposes of said works, without the consent in writing of the Engineer. ...

It also incurred expenses in the amount of $6,042,000 for land, storage tanks, electrical supply services, fire fighting facilities, warehouse, roadways and steam plant in connection with the acquisition and installation of the plant. ... The basic principle in the present connection is that one looks at the character of the receipt from the point of view of the recipient. ...

The Queen, supra, at page 233, seem appropriate in this case: If the Court thus had to withdraw immediately a question of provincial law came before it in connection with the disposition of an action in the Court, not many actions could be taken to their conclusion. ... The respondent is hard-pressed to complain of a dispute that it created and of the process associated with it. [29]       Furthermore, I am not satisfied that in this case the issues in dispute cannot be adequately argued on the basis of the documentary evidence in the record, affidavit evidence and cross-examinations of the affiants, as is the usual procedure in connection with motions in Federal Court, and consequently, that we must deviate from the general scheme applicable to motions. ...

Savics was a partner, the limited partners would be entitled to claim all of the interest and financing charges (the carrying charges) incurred in connection with their investment. [9] The portions of the minutes of settlement that are relevant to the partnerships in which Mr. ... The waivers also included a provision that the waiver of his rights of objection and appeal was subject to the condition: […] that CRA reassesses me as follows: […] (v) unless otherwise agreed to by me, does not make any other adjustment to my tax liability in connection with my investment in, or ownership of, limited partnership units of the Partnership other than consequential adjustments or other adjustments that are not expressly addressed by, and do not create a result that is inconsistent with, any of the preceding terms of the Waiver. [11] Following the execution of the waivers, Mr. ...

The subject-matter of the realization — In this connection the authors comment: “... property which does not yield to its owner an income or personal enjoyment merely by virtue of its ownership is more likely to have been acquired with the object of a deal than property that does.” ... Supplementary work on or in connection with the property realized — The authors' comments under this heading read: If the property is worked up in any way during the ownership so as to bring it into a more marketable condition; or if any special exertions are made to find or attract purchases, such as the opening of an office or large scale advertising, there is some evidence of dealing. ...

The connection between the legal services thus acquired and the taxpayer’s business neither requires nor permits reference to the taxpayer’s state of mind. The nature of that connection is to be found in the objective facts found by his Honour or not in dispute between the parties. ...

Section 58(4) of the Estate Tax Act permits a deduction in connection with.. any property in respect of which a deduction may... be made under any of the paragraphs (a) to (h) of sub-section 1 of Section 7...” and the Section clearly contemplates, and grants a right to, the executors to take a deduction under Section 7 (and to apportion the tax on the balance of the Assets of the Estate) as they see fit. ... It is to be noted that the $625,000 deduction granted under Section 7(1)(b) in connection with the $25,000 per annum payments to Mrs. ...

Rather, the deductions claimed in this case are for the taxes Emergis paid to the US Government on the interest paid by USGP on the Emergis Loan. [14] As part of his textual analysis, the Tax Court Judge found that while the words “in respect of” are very broad, it is still necessary to find a connection between the US taxes paid by Emergis and the dividend income received by NSULC (paragraph 69 of his reasons). [15] In paragraph 71 of his reasons, the Tax Court Judge referred to the specific wording of the exception in issue: [71] However, the reference in subsection 20(12) to the U.S. tax “that can reasonably be regarded as having been paid by a corporation in respect of income from a share of the capital stock of a foreign affiliate of the corporation” clearly suggests to consider whether the income from shares received by a corporation other than the taxpayer can reasonably be regarded as the one in respect of which the U.S. tax [was] paid by the taxpayer claiming the deduction. [16] The Tax Court Judge then considered the flow of funds used to pay the interest and concluded that “there is some connection between the interest income paid by USGP and the dividends paid by LLC to USGP, which were reclaimed and reported by Emergis through its partnership interest in USGP” (paragraph 74 of his reasons). ...