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The witness also pointed out that in calculating revised capital gains for him in 1976 the Minister allowed as costs of sale the cost of options in the amount of $200,000 and cost of employment contracts in the amount of $140,000 thus recognizing those provisions of the sale agreement as being necessary expenses incurred in connection with it, and argues that the apparent loss resulting from the requirement to purchase a claim worth only $600,000 for $1,400,000 should similarly have been deducted as a cost of sale. ... In this connection reference was made to the recent case of Geoffrey Sterling v The Queen, [1983] CTC 220; 83 DTC 5252 (which defendant states is now under appeal) in which my brother Rouleau, J, allowing the adding of interest costs and safekeeping charges to the adjusted cost base of gold bullion purchased by a taxpayer, stated at 5255-6:... ... In the instant matter, agent’s commission, legal fees, etc, were taken into account by the respondent’s assessors and thus they do not arise in connection with the second mortgage received. ...

It was they, however, who had connections and influence through the Ascot Jockey Club which they controlled and of which William Randall is still president, to maintain the exclusive franchise rights provided they were properly operated. ... This is what the Randall brothers did in connection with Caterers. Section 2 provides that partnership is the relation which exists between persons carrying on business in common with the view of profit. ... The appeals against the reassessments for the 1974 to 1977 taxation years are therefore dismissed with costs, only one set of costs being allowed save for disbursements incurred in connection with the second action, T-2209-80. ...

At the end of the day, there still must be some logical connection between the remedy selected and the breach it is designed to address. If there is no connection, the remedy will be outside the range of possible acceptable outcomes. ... To somewhat similar effect, the courts have long held that there must be a rational connection between the breach found by other sorts of labour tribunals and their remedial orders (see e.g. ...

They import such meanings as “in relation to”, “with reference to" or “in connection with”. The phrase “in respect of” is probably the widest of any expression intended to convey some connection between two related subject matters. ... Justice Dickson said at page 5045: The phrase “in respect of", is probably the widest of any expression intended to convey some connection between two related subject matters. ...

The Canada Revenue Agency [CRA] sought to audit Tellza’s goods and services tax/harmonized sales tax [GST/HST] returns for the reporting period November 1, 2016 to January 31, 2018. [2] In connection with its audit, the CRA issued a letter to Tellza on October 4, 2019 under subsection 288(1) of the Excise Tax Act, RSC 1985, c E-15 [ETA] to obtain all of Tellza’s electronic accounting data for this period. ... I add that Tellza did not adduce any evidence contradicting that the letter was issued by an “authorized person,” as contemplated in the relevant provision. [14] Subsection 288(1) essentially permits the authorized person to “inspect, audit or examine the documents, property or processes” of persons with record keeping and reporting obligations under the ETA, including in connection with any claimed rebate or refund such as input tax credits or ITCs. ... À ces fins, la personne autorisée peut: (a) subject to subsection (2), enter any premises or place where any business or commercial activity is carried on, any property is kept, anything is done in connection with any business or commercial activity or any documents are or should be kept; and a) sous réserve du paragraphe (2), pénétrer dans un lieu où est exploitée une entreprise, est exercée une activité commerciale, est gardé un bien, est faite une chose en rapport avec une entreprise ou une activité commerciale ou sont tenus, ou devraient l’être, des documents; (b) require the owner or manager of the property, business or commercial activity and any other person on the premises or in the place to give to the authorized person all reasonable assistance and to answer all proper questions relating to the administration or enforcement of this Part and, for that purpose, require the owner or manager to attend at the premises or place with the authorized person. b) requérir les propriétaire ou gérant du bien, de l’entreprise ou de l’activité commerciale ainsi que toute autre personne présente sur le lieu de lui donner toute l’aide raisonnable et de répondre à toutes les questions pertinentes à l’application ou à l’exécution de la présente partie et, à cette fin, requérir le propriétaire ou le gérant de l’accompagner sur le lieu. ...

On October 13, 1976, the price was reduced to $95,000 the document in connection with same being signed by Gerrit Jan Van de Wygerd. ... The intervenant had a bank account No 3133-870 at the Bank of Montreal, CIL Building branch and on August 13, 1976, had signed a power of attorney form in connection with said account in favour of Gerrit Jan Van de Wygerd and Johannes Van de Wygerd. ... Defendant Gerrit Jan Van de Wygerd acted as her duly authorized agent in connection with listings with the real estate company, although some of the documentation is also signed by her personally. ...

This, however, is an interpretation in connection with taxation statutes which has been established by the courts and is not found, so far as I am aware, in any legislation enacted by the Parliament of Canada. ... Similar observations could be made in connection with students in dentistry. theology. or a number of other professions where students must go through a prescribed course of instruction in order to be fully qualified to offer their services to the public in their chosen field, and surely Parliament must have been aware of this situation when enacting its legislation and when it used the term “in full-time attendance at a(n)... educational institution in Canada in a course at a post-secondary school level.’’ ... He submitted, therefore, that it was very obvious, from the facts in connection with his own case, that it was necessary for him to both “turn his mind to’ and ’’apply himself to" the course in question, and accordingly he contended that the requirements of attendance, as stipulated in the Income Tax Act, were met, beyond any doubt, in the case of the chartered accountant’s course. ...

These sections read as follows: 12. (1) In computing income, no deduction shall be made in respect of (a) an outlay or expense except to the extent that it was made or incurred by the taxpayer for the purpose of gaining or producing income from property or a business of the taxpayer, (b) an outlay, loss or replacement of capital, a payment on account of capital or an allowance in respect of depreciation, obsolescence or depletion except as expressly permitted by this Part, (h) personal or living expenses of the taxpayer except travelling expenses (including the entire amount expended for meals and lodging) incurred by the taxpayer while away from home in the course of carrying on his business, 139. (1) In this Act, (ae) “personal or living expenses” include (i) the expenses of properties maintained by any person for the use or benefit of the taxpayer or any person connected with the taxpayer by blood relationship, marriage or adoption, and not maintained in connection with a business carried on for profit or with a reasonable expectation of profit, Accordingly the basis of this second submission is that even if I conclude that this appellant was in “the business of farming’’, subject expenditures are not deductible because they were not “in connection with a business carried on for profit or with a reasonable expectation of profit” (italics mine). ... Appellant said his purpose was profit, that he eventually expected to make a living on the farm for his family and I accept his evidence in this connection. ... I found his evidence in this connection to be reasonable and realistic. ...

In 1963 he resigned from those companies and established his own business, in connection with which he acquired a real estate company, obtained a real estate agent’s licence, and became a financial consultant tn real estate and mortgage investments, but not in respect of stocks, and he performed management and accounting services for private companies holding real estate. ... The other witness for the respondent, William C Clerkson, testified respecting an assessment made by the Department in 1965 on Mrs Lansdell in connection with her participation, along with her husband, in the purchase of shares of Calix Mines, when they were being underwritten. ... If I accept their evidence in that connection as credible and reasonably acceptable, I should find that the appellant acted on behalf of his wife, rather than for himself, in participating in the venture to purchase the block of 100,000 shares with its free bonus shares, and to exercise accompanying options to purchase an additional 75,000 shares, and that it was Mrs Lansdell, not the appellant, who was entitled to receive and actually did receive the $4,371.98 profit from the venture. ...

Those provisions read as follows: Section 6(1) There shall be included in computing the income of a taxpayer for a taxation year as income from an office or employment such of the following amounts as are applicable: 6(1)(e) where the taxpayer's employer or a person related to the employer made an automobile available to the taxpayer, or to a person related to the taxpayer, in the year, the amount, if any, by which (i) an amount that is a reasonable standby charge for the automobile for the total number of days in the year during which it was made so available exceeds (ii) the total of all amounts, each of which is an amount (other than an expense related to the operation of the automobile) paid in the year to the employer or the person related to the employer by the taxpayer or the person related to the taxpayer for the use of the automobile. 6(2) For the purposes of paragraph (1(e), a reasonable standby charge for an automobile for the total number of days (in this subsection referred to as the “total available days”) in a taxation year during which the automobile is made available to a taxpayer or to a person related to the taxpayer by the employer of the taxpayer or by a person related to the employer (both of whom are in this subsection referred to as the “employer”) shall be deemed to be the amount determined by the formula A/B × [2% × (C × D) + 2/ × 3 (E- F)] where A is the lesser of (a) the total number of kilometres that the automobile is driven (otherwise than in connection with or in the course of the taxpayer's office or employment) during the total available days, and (b) the value determined for B for the year under this subsection in respect of the standby charge for the automobile during the total available days, except that the amount determined under paragraph (a) shall be deeded to be equal to the amount determined under paragraph (b) unless (c) the taxpayer is required by the employer to use the automobile in connection with or in the course of the office or employment, and (d) all or substantially all of the distance travelled by the automobile in the total available days is in connection with or in the course of the office or employment; B is the product obtained when 1,000 is multiplied by the quotient obtained by dividing the total available days by 30 and, if the quotient so obtained is not a whole number and exceeds one, by rounding it to the nearest whole number or, where that quotient is equidistant from two consecutive whole numbers, by rounding it to the lower of those two numbers; C is the cost of the automobile to the employer where the employer owns the vehicle at any time in the year; D is the number obtained by dividing such of the total available days as are days when the employer owns the automobile by 30 and, if the quotient so obtained is not a whole number and exceeds one, by rounding it to the nearest whole number or, where that quotient is equidistant from two consecutive whole numbers, by rounding it to the lower of those two numbers; E is the total of all amounts that may reasonably be regarded as having been payable by the employer to a lessor for the purpose of leasing the automobile during such of the total available days as are days when the automobile is leased to the employer; and F is the part of the amount determined for E that may reasonably be regarded as having been payable to the lessor in respect of all or part of the cost to the lessor of insuring against (a) loss of, or damage to, the automobile, or (b) liability resulting from the use or operation of the automobile. 6(2.1) Where in a taxation year (a) a taxpayer was employed principally in selling or leasing automobiles, (b) an automobile owned by the taxpayer's employer was made available by the employer to the taxpayer or to a person related to the taxpayer, and (c) the employer has acquired one or more automobiles, the amount that would otherwise be determined under subsection (2) as a reasonable standby charge shall, at the option of the employer, be computed as if (d) the reference in the formula in subsection (2) to “2%” were read as a reference to “ 11/2% ”, and (e) the cost to the employer of the automobile were the greater of (i) the quotient obtained by dividing (A) the cost to the employer of all new automobiles acquired by the employer in the year for sale or lease in the course of the employer's business by (B) the number of automobiles described in clause (A), and (ii) the quotient obtained by dividing (A) the cost to the employer of all automobiles acquired by the employer in the year for sale or lease in the course of the employer's business by (B) the number of automobiles described in clause (A). ... Second, “all or substantially all” of the distance travelled by the automobile during the time it was made available to the employee must be in connection with or in the course of his or her employment. ...