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(Educational Connections) v. M.N.R., 2012 TCC 137         Dockets: 2011-593(CPP) 2011-597(EI)   BETWEEN:   WORLDWIDE SCHOOL SEARCH AND RELOCATION SERVICES INC., c.o.b. as EDUCATIONAL CONNECTIONS, Appellant, and   THE MINISTER OF NATIONAL REVENUE, Respondent.  ____________________________________________________________________   Appeal heard on March 7, 2012 at Toronto, Ontario   By: The Honourable J.M. ... Citation: 2012 TCC 137 Date: 20120426 Dockets: 2011-593(CPP) 2011-597(EI)   BETWEEN:   WORLDWIDE SCHOOL SEARCH AND RELOCATION SERVICES INC., c.o.b. as EDUCATIONAL CONNECTIONS, Appellant, and   THE MINISTER OF NATIONAL REVENUE, Respondent.     ... CITATION:                                       2012 TCC 137   COURT FILE NOS.:                         2011-593(CPP) and                                                           2011-597(EI)   STYLE OF CAUSE:                          WORLDWIDE SCHOOL SEARCH AND RELOCATION SERVICES INC., c.o.b. as EDUCATIONAL CONNECTIONS v.                                                           ...

Given the breadth of the phrase “in connection with”, it seems clear to me that the whole of the payments from Hasbro to its purchasing agents can be said to have been made “in connection with the sale of property...”. ... There is no necessity of adding the word ‘purchase’ when referring to something “in connection with” such a contract. ... Sales of goods” would necessarily also be made “in connection with the sale of property”. ...

This connection can be established by a reasonable inference on a balance of probabilities, and does not require that the impugned law be the only or dominant cause of the prejudice suffered by the claimant. [97] A causal connection exists where the state action is a foreseeable and necessary cause of the prejudice, but this is not the only way to establish causation. [98] The burden of establishing this connection is on the Appellants. ... A reasonable inference could be drawn that a sufficient causal connection exists between the requirements and the Appellants’ poverty. ... That being said, a s. 1 analysis requires a rational connection, similar to a s. 7 arbitrariness analysis. ...

Jaques receive a benefit in 1999 in connection with the construction of the Slopes House? ... Issue: Did Park Haven have unreported income in 1997 in connection with Patrick House, and if so, how much? ... Did the Jaques receive shareholder benefits in 1999 in connection with the Furnishings? ...

Notably he added, “ Parliament has added the phrases ‘in the course of’ and ‘by virtue of’ to the phrase ‘in respect of’ in order to emphasize that only the smallest connection to employment is required to trigger the operation of the section.” ... The SCC does specifically speak to this and proceeds to decide Savage on the basis that the benefit therein was a tax exempt “ prize ” per paragraph 56(1)(n). [60]   In any event as to Savage, the broad wording of paragraph 6(1)(a) requires only the slightest connection between the benefit and employment. ... And, at risk of undue repetition, that connection was readily met for Mr. ...

Facts in connection with the fair market value of the Complex [4]      The following is a comparison of the conclusions of the Minister's appraiser, Mr. ... Facts in connection with penalties and substantial completion [8]      Mr. ... This advice was given specifically in connection with the Complex. The Appellant suggests I should give little weight to this meeting as Mr. ...

Pursuant to these conditions, CDPQ's subscription was conditional on Laurentian Bank's reimbursement of certain fees and expenses to be incurred by CDPQ in connection with the subscription. ... It may not always be easy to decide whether an expense has so risen but it seems to me that the words "in the course of" in paragraph 11(1)(cb) [now paragraph 20(1)(e)] are not a reference to the time when the expenses are incurred but are used in the sense of "in connection with" or "incidental to" or "arising from" and refer to the process of carrying out or the things which must be undertaken to carry out the issuing or selling or borrowing for or in connection with which the expenses are incurred. ... "in connection with" or "incidental to" or "arising from". [76] In the light of this, an expense incurred in the course of an issuance of shares could be deductible pursuant to paragraph 20(1)(e) of the ITA insofar as the evidence shows that the expense was incurred by the taxpayer "in connection with" the issuance of shares of its capital stock or that it is an expense "incidental to" or "arising from" the issuance of the shares. ...

Judge Porter decided each haircutter was involved in a business activity in connection with a hairdressing establishment and that each provided services that are normally provided therein. ... 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. ...

The remedial and repair work were not directly related to the move but were incurred in connection with the move to preserve or enhance value. ... The Minister of National Revenue, [1] a decision of the Tax Review Board, as authority for the proposition that moving expenses embraced only those expenditures directly related to the sale of the old residence and not all expenses or costs incurred in connection with its sale ...

She explained that the calculation of a reasonable standby charge provided for in subsection 6(2) of the Act does not take into account the personal use percentage of total kilometrage except where the employer requires the taxpayer to use the automobile in connection with or in the course of a taxpayer's office or employment and if all or substantially all of the distance travelled by the automobile is in connection with or in the course of the office or employment. ... 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. ...   [20]    In connection to that percentage, reference must be made to a decision by our Court in McDonald v. ...