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Subsection 178(2) reads 178(2) Costs payable by Minister in certain cases- Where, on an appeal by the Minister, other than by way of cross-appeal, from a decision of the Tax Court of Canada, the amount of (a) tax, refund or amount payable under subsection 196(2) (in the case of an assessment of the tax or determination of the refund or the amount payable, as the case may be) that is in controversy does not exceed $10,000, or (b) loss (in the case of a determination of the loss) that is in controversy does not exceed $20,000, the Federal Court, in delivering judgment disposing of the appeal, shall order the Minister to pay all reasonable and proper costs of the taxpayer in connection therewith. ...

I fully endorse the connection made by the Federal Court between that case and Mr. ...

The slight economic gains and losses derived from the exposure to the interest rate differential were merely incidental and bore little connection with the gains and losses that Mr. ...

In connection with this modification, the Directorate advised the appellant that “[c]haritable organizations may not directly provide cash (funds) to non-qualified donees, in this case the poor [in Israel]…” but could provide them with furniture and clothing as the appellant proposed (Appeal Book Vol. ...

The Information to Obtain sworn in support identified the Respondent in connection with a CID investigation into tax evasion by a client of Corporate House. ...

After reviewing the case law, it held that the cornerstone for this broad language is the existence of “a connection between the diminishment of the property of one person and the increase in the property of another person” (Reasons, para. 131). ...

In this connection, it is convenient to refer to the standard dictionary definition in both official languages. ...

I will cite only five examples from the amended 1927 consolidation (Income War Tax Act, R.S.C. 1927, c. 97 as amended). (1) In the complex definition of "personal corporation" in paragraph 2(i)(i), there is a reference to "bonds, stocks or shares, debentures, mortgages, hypothecs, bills, notes or other similar property". (2) The scheme for the taxation of personal corporations required a determination of the value of the property of the corporation acquired from shareholders. (3) Paragraph 6(c) prohibited the deduction of "the annual value of property, real or personal, except rent actually paid for the use of such property, used in connection with the business to earn the income subject to taxation". (4) Paragraph 6(d) prohibited the deduction of "carrying charges or expenses of unproductive property or assets not acquired for the purposes of a trade, business or calling". (5) Subsection 3(f), added by S.C. 1934, c. 55, provides that income includes "rents, royalties, annuities or other like periodical receipts which depend upon the production or use of any real or personal property, notwithstanding that the same are payable on account of the use or sale of any such property. ...

Paragraph 245(3)(b) provides no guidance with respect to the degree of connection or relationship that is required before transactions will be regarded as constituting a series. ... As long as the transaction has some connection with the common law series, it will, if it was completed in contemplation of the common law series, be included in the series by reason of the deeming effect of subsection 248(10). ...

That sum appears to me to have been paid for the establishment of a permanent physical connection between the respondent’s plant and that of Anglo-Canadian. ... In that connection I need only refer to the definitions of disposition contained in subclauses (I), (ii) and (ix) of clause (f) of section 1. ...