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S.C. 1970-71-72, c. 63) (the "Act") and subsequently for the 1983,1984 and 1985 taxation years: 9.(1) Subject to this Part, a taxpayer’s income for a taxation year from a business or property is his profit therefrom for the year. (2) Subject to section 31, a taxpayer’s loss for a taxation year from a business or property is the amount of this loss, if any, for the taxation year from that source computed by applying the provisions of this Act respecting computation of income from that source mutatis mutandis, 18.(1) In computing the income of a taxpayer from a business or property 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 the business or property; (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 Pis business; 20.(1) Notwithstanding paragraphs 18(1)(a), (b) and (h), in computing a taxpayer's income for a taxation year from a business or property, there may be deducted such of the following amounts as are wholly applicable to that source or such part of the following amounts as may reasonably be regarded as applicable thereto: (a) such part of the capital cost to the taxpayer of property, or such amount in respect of the capital cost to the taxpayer of property, if any, as is allowed by regulation; 248.(1) In this Act, “business” includes a profession, calling, trade, manufacture or undertaking of any kind whatever and, except for the purposes of paragraph 18(2)(c), an adventure or concern in the nature of trade but does not include an office or employment; "personal or living expenses" includes (a) 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, (b) the expenses, premiums or other costs of a policy of insurance, annuity contract or other like contract if the proceeds of the policy or contract are payable to or for the benefit of the taxpayer or a person connected with him by blood relationship, marriage or adoption, and (c) expenses of properties maintained by an estate or trust for the benefit of the taxpayer as one of the beneficiaries; The regulations in these income tax appeals are regulations 1100(1)(v), 1100(3), 1101(2a) and 1102(1)(c) of the Income Tax Regulations, as amended for the 1983, 1984 and 1985 taxation years. ... See also paragraph 139(1)(ae) of the Income Tax Act which includes as "personal and living expenses” and therefore not deductible for tax purposes, the expenses of properties maintained by the taxpayer for his own use and benefit, and not maintained in connection with a business carried on for profit or with a reasonable expectation of profit. ...

It is argued that the plaintiff's main activity is the provision of services and that the production of "goods" in connection therewith is only incidental to the service being provided. ... As counsel for the plaintiff pointed out, under such a regime, a manufacturer or processor of a product (e.g., a chemical fertilizer) who also provided a service in connection therewith (e.g., spreading the fertilizer for his customers) would be denied the processing tax deduction. ...

Now, whilst it is asserted by some that the republic to the south has frequently exhibited more tendencies to dominate than to trade or to compete in business, that country has not yet sought to tax foreign corporations at random, but only those with some connection with the U.S. In the case of Norsk, its connection is carrying on its business from its place of management situated in the U.S.A. and in generating income effectively connected with its business. ...

Jones, but also from a letter addressed to him on March 15, 1979, by his own solicitor (of the firm Thorsteinsson, Mitchell, Little, O'Keefe & Davidson) in connection with Mr. ... In addition to the $1,000,000 received by Blake for the sale of the shares in Taiga, "the company also received $250,000 from Taiga in connection with management services to be rendered". ...

The purposes and objects of said corporation as set out in its Letters Patent are as follows: (a) To carry on, whether as principals or agents, the business of an investment company and, in that connection, to purchase, underwrite, take in exchange, subscribe for or otherwise acquire upon and subject to such terms and conditions as may seem expedient, hold, sell, alienate and otherwise dispose of shares, stocks, bonds, debentures, debenture stock, warrants, option certificates or other evidences of indebtedness, securities and investments of every kind and to manage, sell, alienate or otherwise dispose of any of the assets of the Company from time to time and generally to make investments of the funds or moneys of the Company in any kind of property, real and immoveable, personal and moveable, and to change, alter, vary or realize upon any investments from time to time and to reinvest the proceeds thereof. ... The relevant portions of this Agreement read as follows: WHEREAS the Purchaser is a wholly owned subsidiary of the Vendor and has been formed for the purpose of taking over and carrying on the mining exploration and development work of the Vendor, and will reimburse the Vendor for all expenditures made by it in that connection, the whole with the same effect and to the same extent as though such exploration and development work had always been carried on by the Purchaser. ...

In this connection applicants referred to the text book H.W.R. Wade, Administrative Law, Fourth Edition, in which at page 544 he states: Every citizen has standing to invite the court to prevent some abuse of power, and in doing so he may claim to be regarded not as a meddlesome busybody but as a public benefactor. ... He points out that subsection 192(2) of the Act requires the taxpayer to pay 50 per cent of the amounts received with respect to a share or debt obligation issued in connection with the scientific tax credit before the last day of the following month. ...

See also 139(1)(ae) of the Income Tax Act which includes as "personal and living expenses” and therefore not deductible for tax purposes, the expenses of properties maintained by the taxpayer for his own use and benefit, and not maintained in connection with a business carried on for profit or with a reasonable expectation of profit. ... In this connection, the Court must nevertheless keep in mind a statement in the Federal Court by Mahoney, J. ...

(i) of the chairperson of the Board, where no public hearing is held by the Board in connection with the application for the licence, or (ii) of the Minister, where a public hearing is held by the Board in connection with the application for the licence. 6) La délivrance est subordonnée à l'agrément_: a) dans le cas d'un permis de type A, du ministre; b) dans le cas d'un permis de type B, du président de l'Office si la demande ne fait pas l'objet d'une audience publique par l'Office ou du ministre dans le cas contraire. [...] [13]            Subsection 56(1) of the Nunavut Act provides that certain licences issued by the NWB are subject to the approval of the Minister: 56. (1) The issuance, amendment, renewal and cancellation of a type A licence and, if a public hearing is held, a type B licence are subject to the approval of the Minister. 56. (1) Sont subordonnés à l'agrément du ministre la délivrance, le renouvellement, la modification et l'annulation d'un permis de type A et, dans les cas où une enquête publique est tenue, de type B. [14]            The question is whether, in the interim period, after the creation of the NWB and before the coming into force of the Nunavut Waters Act, the provisions of the Agreement operate to remove the requirement for Ministerial approval. [15]            With respect to this question, the Applicant's submissions can be grouped into the following broad areas of concern:            1.         ...

The Agreement included as Schedule "A" a written declaration of trust in connection with the Account. ... The Defendant had no fiduciary obligation to the Council in connection with the Agreement other than an obligation to operate the Account as agreed. ...

What is the logic of allowing the person with the more tenuous connection with Canada to take advantage of a relieving provision while denying it to someone with a more solid connection with this country? ...