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  [17]          In connection with the “ formula ” or position adopted by the Appellants in determining their net income for the years in question, I refer to the decision of Justice James Russell of the Federal Court in Ugro v Minister of National Revenue, 2009 FC 826, 2010 D.T.C. 5002. ... Ugro had appealed to the Federal Court in connection with the Minister’s decision under the Fairness Legislation. ...

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.*                                                              [Emphasis added, footnotes omitted ...

to bring into close association or connection:  The research center is affiliated with the university.   2. to attach or unite on terms of fellowship; associate   From these definitions, it appears that “affiliated” in its ordinary sense means “associated” or “closely connected with” ... Furthermore, the language used by FIC in its written materials was descriptive of a close relationship or connection between FIC and SFU, and it is immaterial that it referred to itself as being associated or partnered with SFU rather than affiliated ...

FACTS   [1]               On November 3, 2009, the Appellant, Ronald Cowell (“Cowell”), filed Notices of Appeal in connection with Notices of Reassessment issued for his 1990, 1991, 1992 and 1993 taxation years ...   [2]               On November 3, 2009, the Appellant, Dial Drug Stores Limited (“Dial”), filed Notices of Appeal in connection with Notices of Reassessment issued for the 1990, 1991, 1992, 1993 and 1994 taxation years ...

Paragraph 8(1)(f) of the Act (which applies to persons who are “employed in the year in connection with the selling of property or negotiating of contracts for the taxpayer's employer”) refers to amounts expended. ... However the Appellant was not “employed in the year in connection with the selling of property or negotiating of contracts for [his] employer” and therefore paragraph 8(1)(f) of the Act does not apply to the Appellant. ...

BEFORE AMDENDMENT IN 2006   118.3 (1)           Where (a)        an individual has a severe and prolonged mental or physical impairment, (a.1)     the effects of the impairment are such that the individual's ability to perform a basic activity of daily living is markedly restricted, (a.2)     a medical doctor, or where the impairment is an impairment of sight, a medical doctor or an optometrist, has certified in prescribed form that the individual has a severe and prolonged mental or physical impairment the effects of which are such that the individual's ability to perform a basic activity of daily living is markedly restricted, (b)        the individual has filed for a taxation year with the Minister the certificate described in paragraph (a.2), and (c)        no amount in respect of remuneration for an attendant or care in a nursing home, in respect of the individual, is included in calculating a deduction under section 118.2 (otherwise than by reason of paragraph (2)(b.1) thereof) for the year by the individual or by any other person, for the purposes of computing the tax payable under this Part by the individual for the year, there may be deducted an amount determined by the formula A x $4,118 where A is the appropriate percentage for the year.   118.3(4)           Where a claim under this section or under section 118.8 is made in respect of an individual 's impairment   (a)        if the Minister requests in writing information with respect to the individual 's impairment, its effects on the individual and, where applicable, the therapy referred to in paragraph (1)(a.1) that is required to be administered, from any person referred to in subsection (1) or (2) or section 118.8 in connection with such a claim, that person shall provide the information so requested to the Minister in writing; and   (b)        if the information referred to in paragraph (a) is provided by a person referred to in paragraph (1)(a.2), the information so provided is deemed to be included in a certificate in prescribed form.   118.4 (1)           For the purposes of subsection 6(16), sections 118.2 and 118.3 and this subsection, (a)        an impairment is prolonged where it has lasted, or may reasonably be expected to last, for a continuous period of at least 12 months; (b)        an individual's ability to perform a basic activity of daily living is markedly restricted only where all or substantially all of the time, even with therapy and the use of appropriate devices and medication, the individual is blind or is unable (or requires an inordinate amount of time) to perform a basic activity of daily living; (c)        a basic activity of daily living in relation to an individual means (i)         perceiving, thinking and remembering, (ii)        feeding and dressing oneself, (iii)       speaking so as to be understood, in a quiet setting, by another person familiar with the individual, (iv)       hearing so as to understand, in a quiet setting, another person familiar with the individual, (v)        eliminating (bowel or bladder functions), or (vi)       walking; and (d)    for greater certainty, no other activity, including working, housekeeping or a social or recreational activity, shall be considered as a basic activity of daily living.   AFTER AMENDMENT IN 2006 (CURRENT VERSION) 118.3 (1)           Where (a)        an individual has one or more severe and prolonged impairments in physical or mental functions, (a.1)     the effects of the impairment or impairments are such that the individual’s ability to perform more than one basic activity of daily living is significantly restricted where the cumulative effect of those restrictions is equivalent to having a marked restriction in the ability to perform a basic activity of daily living or are such that the individual’s ability to perform a basic activity of daily living is markedly restricted or would be markedly restricted but for therapy that (i)         is essential to sustain a vital function of the individual, (ii)        is required to be administered at least three times each week for a total duration averaging not less than 14 hours a week, and (iii)       cannot reasonably be expected to be of significant benefit to persons who are not so impaired, (a.2)     in the case of an impairment in physical or mental functions the effects of which are such that the individual’s ability to perform a single basic activity of daily living is markedly restricted or would be so restricted but for therapy referred to in paragraph (a.1), a medical practitioner has certified in prescribed form that the impairment is a severe and prolonged impairment in physical or mental functions the effects of which are such that the individual’s ability to perform a basic activity of daily living is markedly restricted or would be markedly restricted, but for therapy referred to in paragraph (a.1), where the medical practitioner is a medical doctor or, in the case of (i)         a sight impairment, an optometrist, (ii)        a speech impairment, a speech-language pathologist, (iii)       a hearing impairment, an audiologist, (iv)       an impairment with respect to an individual’s ability in feeding or dressing themself, an occupational therapist, (v)        an impairment with respect to an individual’s ability in walking, an occupational therapist, or after February 22, 2005, a physiotherapist, and (vi)       an impairment with respect to an individual’s ability in mental functions necessary for everyday life, a psychologist, (a.3)     in the case of one or more impairments in physical or mental functions the effects of which are such that the individual’s ability to perform more than one basic activity of daily living is significantly restricted, a medical practitioner has certified in prescribed form that the impairment or impairments are severe and prolonged impairments in physical or mental functions the effects of which are such that the individual’s ability to perform more than one basic activity of daily living is significantly restricted and that the cumulative effect of those restrictions is equivalent to having a marked restriction in the ability to perform a single basic activity of daily living, where the medical practitioner is, in the case of (i)         an impairment with respect to the individual’s ability in feeding or dressing themself, or in walking, a medical doctor or an occupational therapist, and (ii)        in the case of any other impairment, a medical doctor, has certified in prescribed form that the impairment is a severe and prolonged mental or physical impairment the effects of which are such that the individual’s ability to perform a basic activity of daily living is markedly restricted or would be markedly restricted but for therapy referred to in paragraph (a.1), (b)        the individual has filed for a taxation year with the Minister the certificate described in paragraph (a.2) or (a.3), and (c)        no amount in respect of remuneration for an attendant or care in a nursing home, in respect of the individual, is included in calculating a deduction under section 118.2 (otherwise than because of paragraph 118.2(2)(b.1)) for the year by the individual or by any other person, there may be deducted in computing the individual’s tax payable under this Part for the year the amount determined by the formula A × (B + C) where A is the appropriate percentage for the year, B is $6,000, and C is (a)        where the individual has not attained the age of 18 years before the end of the year, the amount, if any, by which (i)         $3,500 exceeds (ii)        the amount, if any, by which (A) the total of all amounts each of which is an amount paid in the year for the care or supervision of the individual and included in computing a deduction under section 63, 64 or 118.2 for a taxation year exceeds (B) $2,050, and (b)        in any other case, zero.   118.3(4)           Where a claim under this section or under section 118.8 is made in respect of an individual 's impairment   (a)        if the Minister requests in writing information with respect to the individual 's impairment, its effects on the individual and, where applicable, the therapy referred to in paragraph (1)(a.1) that is required to be administered, from any person referred to in subsection (1) or (2) or section 118.8 in connection with such a claim, that person shall provide the information so requested to the Minister in writing; and   (b)        if the information referred to in paragraph (a) is provided by a person referred to in paragraph (1)(a.2), the information so provided is deemed to be included in a certificate in prescribed form.   118.4 (1)           For the purposes of subsection 6(16), sections 118.2 and 118.3 and this subsection, (a)        an impairment is prolonged where it has lasted, or can reasonably be expected to last, for a continuous period of at least 12 months; (b)        an individual’s ability to perform a basic activity of daily living is markedly restricted only where all or substantially all of the time, even with therapy and the use of appropriate devices and medication, the individual is blind or is unable (or requires an inordinate amount of time) to perform a basic activity of daily living; (b.1)     an individual is considered to have the equivalent of a marked restriction in a basic activity of daily living only where all or substantially all of the time, even with therapy and the use of appropriate devices and medication, the individual’s ability to perform more than one basic activity of daily living (including for this purpose, the ability to see) is significantly restricted, and the cumulative effect of those restrictions is tantamount to the individual’s ability to perform a basic activity of daily living being markedly restricted; (c)        a basic activity of daily living in relation to an individual means (i)         mental functions necessary for everyday life, (ii)        feeding oneself or dressing oneself, (iii)       speaking so as to be understood, in a quiet setting, by another person familiar with the individual, (iv)       hearing so as to understand, in a quiet setting, another person familiar with the individual, (v)        eliminating (bowel or bladder functions), or (vi)       walking; (c.1)     mental functions necessary for everyday life include (i)         memory, (ii)        problem solving, goal-setting and judgement (taken together), and (iii)       adaptive functioning; (d)        for greater certainty, no other activity, including working, housekeeping or a social or recreational activity, shall be considered as a basic activity of daily living; and (e)        feeding oneself does not include (i)         any of the activities of identifying, finding, shopping for or otherwise procuring food, or (ii)        the activity of preparing food to the extent that the time associated with the activity would not have been necessary in the absence of a dietary restriction or regime; and (f)        dressing oneself does not include any of the activities of identifying, finding, shopping for or otherwise procuring clothing. ...

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 ...

Feil has also signed certificates on Feil & Co. letterhead in respect of Avtel Financial Corporation in connection with RRSP investments by other investors ... Feil of Feil & Co. by telephone in connection with the actions of the Canada Revenue Agency (the “CRA”) against the investors. ...

No issue can be taken with the fact that the appellant was employed in both taxation years in connection with the sale of motor vehicles for Taylor Ford in Moncton and that he was remunerated in whole by commissions fixed by reference to the volume of his sales. ...   [23]     The relevant subsections of the Act read as follows:   8(1)(f) Sales expenses — 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 those 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);   8 (1)(h) Travel expenses — where the taxpayer, in the year,   (i)         was ordinarily required to carry on the duties of the office or employment away from the employer's place of business or in different places, and (ii)        was required under the contract of employment to pay the travel expenses incurred by the taxpayer in the performance of the duties of the office or employment, amounts expended by the taxpayer in the year (other than motor vehicle expenses) for travelling in the course of the office or employment, except where the taxpayer   (iii)       received an allowance for travel expenses that was, because of subparagraph 6(1)(b)(v), (vi) or (vii), not included in computing the taxpayer's income for the year, or (iv)       claims a deduction for the year under paragraph (e), (f) or (g);   8 (1)(h.1) Motor vehicle travel expenses — where the taxpayer, in the year,   (i)         was ordinarily required to carry on the duties of the office or employment away from the employer's place of business or in different places, and (ii)        was required under the contract of employment to pay motor vehicle expenses incurred in the performance of the duties of the office or employment, amounts expended by the taxpayer in the year in respect of motor vehicle expenses incurred for travelling in the course of the office or employment, except where the taxpayer (iii)       received an allowance for motor vehicle expenses that was, because of paragraph 6(1)(b), not included in computing the taxpayer's income for the year, or (iv)       claims a deduction for the year under paragraph (f);   8 (1)(i) Dues and other expenses of performing duties — amounts paid by the taxpayer in the year as   (i)         annual professional membership dues the payment of which was necessary to maintain a professional status recognized by statute, (ii)        office rent, or salary to an assistant or substitute, the payment of which by the officer or employee was required by the contract of employment, (iii)       the cost of supplies that were consumed directly in the performance of the duties of the office or employment and that the officer or employee was required by the contract of employment to supply and pay for, (iv)       annual dues to maintain membership in a trade union as defined (A)    by section 3 of the Canada Labour Code, or (B)    in any provincial statute providing for the investigation, conciliation or settlement of industrial disputes, or to maintain membership in an association of public servants the primary object of which is to promote the improvement of the members' conditions of employment or work, (v)        annual dues that were, pursuant to the provisions of a collective agreement, retained by the taxpayer's employer from the taxpayer's remuneration and paid to a trade union or association designated in subparagraph (iv) of which the taxpayer was not a member, (vi)       dues to a parity or advisory committee or similar body, the payment of which was required under the laws of a province in respect of the employment for the year, and (vii)      dues to a professions board, the payment of which was required under the laws of a province, to the extent that the taxpayer has not been reimbursed, and is not entitled to be reimbursed in respect thereof;   8(4) Meals — An amount expended in respect of a meal consumed by a taxpayer who is an officer or employee shall not be included in computing the amount of a deduction under paragraph (1)(f) or (h) unless the meal was consumed during a period while the taxpayer was required by the taxpayer's duties to be away, for a period of not less than twelve hours, from the municipality where the employer's establishment to which the taxpayer ordinarily reported for work was located and away from the metropolitan area, if there is one, where it was located.   8(10) Certificate of employer — An amount otherwise deductible for a taxation year under paragraph (1)(c), (f), (h) or (h.1) or subparagraph (1)(i)(ii) or (iii) by a taxpayer shall not be deducted unless a prescribed form, signed by the taxpayer's employer certifying that the conditions set out in the applicable provision were met in the year in respect of the taxpayer, is filed with the taxpayer's return of income for the year.   8(13) Work space in home — Notwithstanding paragraphs (1)(f) and (i),   (a)      no amount is deductible in computing an individual's income for a taxation year from an office or employment in respect of any part (in this subsection referred to as the "work space") of a self-contained domestic establishment in which the individual resides, except to the extent that the work space is either            (i)      the place where the individual principally performs the duties of the office or employment, or          (ii)     used exclusively during the period in respect of which the amount relates for the purpose of earning income from the office or employment and used on a regular and continuous basis for meeting customers or other persons in the ordinary course of performing the duties of the office or employment;   (b)      where the conditions set out in subparagraph (a)(i) or (ii) are met, the amount in respect of the work space that is deductible in computing the individual's income for the year from the office or employment shall not exceed the individual's income for the year from the office or employment, computed without reference to any deduction in respect of the work space; and (c)     any amount in respect of a work space that was, solely because of paragraph (b), not deductible in computing the individual's income for the immediately preceding taxation year from the office or employment shall be deemed to be an amount in respect of a work space that is otherwise deductible in computing the individual's income for the year from that office or employment and that, subject to paragraph (b), may be deducted in computing the individual's income for the year from the office or employment.     ...

Hervieux regularly used a number of the tools he owned in connection with his contracting construction and renovation business. ... Laberge bought some new tools needed in connection with Mr. Hervieux’s work as well as disposable items like blades and bits although Mr.  ...