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Beyond that, the sections of the legislation are as follows: Taxes in Respect of Registered Plans 207.01 advantage, in relation to a registered plan, means (the “TFSA Advantage”) (a) any benefit, loan or indebtedness that is conditional in any way on the existence of the registered plan, other than [enumerated exceptions in (i)-(v)]; (b) a benefit that is an increase in the total fair market value of the property held in connection with the registered plan if it is reasonable to consider, having regard to all the circumstances, that the increase is attributable, directly or indirectly, to (i) a transaction or event or a series of transactions or events that (A) would not have occurred in a normal commercial or investment context in which parties deal with each other at arm’s length and act prudently, knowledgeably and willingly, and (B) had as one of its main purposes to enable a person or a partnership to benefit from the exemption from tax under Part I of any amount in respect of the registered plan, (ii) a payment received as, on account or in lieu of, or in satisfaction of, a payment (A) for services provided by a person who is, or who does not deal at arm’s length with, the controlling individual of the registered plan, or (B) of interest, of a dividend, of rent, of a royalty or of any other return on investment, or of proceeds of disposition, in respect of property (other than property held in connection with the registered plan) held by a person who is, or who does not deal at arm’s length with, the controlling individual of the registered plan, (iii) a swap transaction, or (iv) specified non-qualified investment income that has not been paid from the registered plan to its controlling individual within 90 days of receipt by the controlling individual of a notice issued by the Minister under subsection 207.06(4); (c) a benefit that is income (determined without reference to paragraph 82(1)(b)), or a capital gain, that is reasonably attributable, directly or indirectly, to (i) a prohibited investment in respect of the registered plan or any other registered plan of the controlling individual, (ii) in the case of a registered plan that is not a TFSA, an amount received by the controlling individual of the registered plan, or by a person who does not deal at arm’s length with the controlling individual (if it is reasonable to consider, having regard to all the circumstances, that the amount was paid in relation to, or would not have been paid but for, property held in connection with the registered plan) and the amount was paid as, on account or in lieu of, or in satisfaction of, a payment (A) for services provided by a person who is, or who does not deal at arm’s length with, the controlling individual of the registered plan, or (B) of interest, of a dividend, of rent, of a royalty or of any other return on investment, or of proceeds of disposition, or (iii) a deliberate over-contribution; (d) a registered plan strip in respect of the registered plan; and (e) a prescribed benefit.  ... Liability for tax (3) Each controlling individual of a registered plan in connection with which a tax is imposed under subsection (1) is jointly and severally, or solidarily, liable to pay the tax except that, if the advantage is extended by the issuer, carrier or promoter of the registered plan or by a person with whom the issuer, carrier or promoter is not dealing at arm’s length, the issuer, carrier or promoter, and not the controlling individual, is liable to pay the tax. ... (c) Purpose [49] The Appellant’s purposive arguments centre on the purpose of the TFSA Charge, and, in connection to it, its effect. ...

Frappier's claim is made under paragraph 8(1)(f) of the Income Tax Act, which reads: In computing a taxpayer's income for a taxation year from an office or employment, 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: (f) — where the taxpayer was employed in the year in connection with the selling of property or negotiating of contracts for the taxpayer's employer, and (i) under the contract of employment was required to pay the taxpayer's own expenses, (ii) was ordinarily required to carry on the duties of the employment away from the employer's place of business, (iii) was remunerated in whole or part by commissions or other similar amounts fixed by reference to the volume of the sales made or the contracts negotiated, and (iv) was not in receipt of an allowance for travel expenses in respect of the taxation year that was, by virtue of subparagraph 6(1)(b)(v), not included in computing the taxpayer's income, amounts expended by the taxpayer in the year for the purpose of earning the income from the employment (not exceeding the commissions or other similar amounts referred to in subparagraph (iii) and received by the taxpayer in the year) to the extent that such amounts were not (v) outlays, losses or replacements of capital or payments on account of capital, except as described in paragraph (j), (vi) outlays or expenses that would, by virtue of paragraph 18(1)(l), not be deductible in computing the taxpayer's income for the year if the employment were a business carried on by the taxpayer, or (vii) amounts the payment of which reduced the amount that would otherwise be included in computing the taxpayer's income for the year because of paragraph 6(1)(e). 4 Although the considerations that underlie the determination that must be made here are the same whether her income is from a business (section 9) or from employment (section 8) it was agreed that the case should proceed on the basis that she was employed by a brokerage firm and that it was therefore unnecessary to consider whether her income was from a business. ...

Under the terms of the licence agreement, the partnership was obligated (i) to commence operation of the hotel not later than thirty days following completion of the buildings; and (ii) to conform to the standards of quality and design for all furniture, furnishings, supplies and equipment used in connection with such business as approved by Orangeroof. ...

The Appellant did not have any connection to any of the companies identified above and he had simply contacted CIBC Investors Services Inc. to acquire the shares of these companies. ...

Yours truly,   Signature     Ann Marie Murell Senior Manager Human Resources   ISSUE   [6]   The issue in this appeal is whether the benefit received in connection with the RSUs should be valued when the award was granted or when the award vested.         ...

The fact that mobile homes may have sewer, water or electrical connections is more in the nature of the users' convenience.... in my view they are not buildings or structures. [14]     Counsel referred also to R. v. ...

ML explained that it was not its policy to waive payment of either interest or principal and asserted that there was no connection between its position as mortgagee and as investor in FT. ...

He testified that he did incur expenses in looking for work, however, and, encouraged by his “accountant”, he claimed those expenses, and many that had no connection to his search for work, as the expenses of Enterprises. ...

Blackburn claimed a deduction from income under paragraph 8(1) (b) of the Income Tax Act (the Act) for legal fees that he had paid in connection with a charge of dangerous driving that had been preferred against him on October 31, 1997. ...

Snowball and Carefoot and their respective spouses and not STE; (c) the financial statements of STE record no property relating to the real estate ventures and no revenues or expenses in connection with them; and (d) there was no written partnership agreement between STE and Mr. ...