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Further, the appellants contend that interest expenses incurred by them during the 1982 taxation year relating to advances to Eletex to permit Eletex to discharge its obligation to the CIBC are deductible from their income from Bathurst notwithstanding Eletex’s bankruptcy because Eletex was simply an offshoot of Bathurst and income and losses realized in connection with it formed part of the same source of income. ... Earlier, at page 343 (D.T.C. 1243), his Lordship in denying a deduction for interest on money lent by the appellant corporation to its subsidiary had this to say: No doubt there is in fact a casual connection between the purchase of the stock and the benefits ultimately received; but the statutory language cannot be extended to such a remote consequence; it could be carried to any length in a chain of subsidiaries; and to say that such a thing was envisioned by the ordinary expression used in the statute is to speculate and not interpret. ...

Berger continued to travel with the Maple Leafs to their away games, relying on his connections with directors of media relations with the various NHL teams to provide access, as he no longer had the media accreditation that he had had with FAN 590. ... For over 20 years he got paid for reporting on sports stories, mainly in connection with the Maple Leafs (I cannot resist adding that it is taking immense internal restraint to not comment on the ongoing Leafs “legacy”). ...

In connection with the appellant's first argument, I must determine to whom the services were provided. ... In connection with the 80/20 split, Dick was asked in cross-examination if the profit allocated to the appellant would be substantially less if the appellant were owned by persons outside his family; and he answered "it probably would be”. ...

As security for payment of the principal of the debenture, Glenwood mortgaged and charged to and in favour of the holders by way of a fixed and specific mortgage and charge “all goods, chattels and personal property situate in the Province of New Brunswick used or useful in connection with the business of the Company" listed in a schedule to the debenture and also by way of a first floating charge, “its undertaking and all its property and assets, being personal and moveable only,... ... She did not receive any reward in connection with these term deposits other than the interest to which she was entitled before giving in trust to her husband these moneys representing the proceeds resulting from her cashing in the term deposits. ...

For example, to avoid death taxes in connection with foreign real estate, it is common to form a private corporation in Canada for the sole purpose of holding all the issued shares of a foreign private corporation which, in turn, is formed for the sole purpose of holding a foreign vacation property. ... The fact that a corporation, carrying on an active business and holding certain property (i.e. investments) unrelated to the business, uses the income from the property in connection with the operation of the active business does not mean that the property is “incident to or pertains to" the active business. ...

Counsel for the appellant did not in connection with that hypothesis refer to any provisions of the Income Tax Act or any tax principle that would have justified a departure from generally accepted accounting principles. ... In this connection, I have in mind the approach adopted by Estey, J. in the decision of the Supreme Court of Canada in the case of Stubart Investments Ltd. v. ...

At paragraph 54, the Supreme Court went on to say: “... in recognition and enforcement proceedings, order and fairness are protected by ensuring that a real and substantial connection existed between the foreign court and the underlying dispute. If such a connection did not exist, or if the defendant was not present in or did not attorn to the foreign jurisdiction, the resulting judgment will not be recognized and enforced in Canada.” [13]         Thus, relying on comity is a balancing exercise. ...

He referred in this connection to the decision of this Court in Business Art Inc. v. M.N.R., 86 DTC 1842, and in particular to page 1848: I cannot subscribe to the theory that in such an example the non-interest bearing loans were not incurred for the purpose of earning income from property; if the loans were not advanced the corporation may have become bankrupt and the shares may have become worthless. [32] He argued that the cases do not require a direct connection between the loan and the income. ...

The above passage deals with only negligence or the failure to exercise reasonable care in connection with opening a statute-barred year. ... Once she proved that the Appellant had been untruthful with respect to certain expenses, and that other substantial amounts had no supporting receipts, the onus was on the Appellant to prove that the various credit card vouchers had a connection with the Appellant’s business. ...

This was in connection with a legal action brought by Mr. Merchant against the Canadian Broadcasting Corporation. ... Merchant’s wife allegedly for doing some filing in connection with some board that Mr. ...