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In this connection, let us first recall that the terms “where a person has...transferred property” used in subsection 160(1) of the Act are qualified by the expression “directly or indirectly, by means of a trust or by any other means”. ... 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 first being where Courts insist on an immediate and direct connection of expense to income. ... The direct connection between the two in most instances was vague. Mr. ... There must be a more immediate connection between the expense and income than what was presented. ...

At pages 486-87 (C.T.C. 314, D.T.C. 5216): There has been difference of opinion on whether the word “ combination” in subsection 13(1) requires some “connection” by way of physical relationship or integration or interconnection between farming and the subordinate activity which provides another source of income. Paragraph 3(f) of the Income War Tax Act of 1917, as amended, made reference to” connection” in defining the permissible deductions from income derived from the chief business, trade, profession or occupation of the taxpayer in determining his taxable income. ... We have it on high authority that there is no reason why there should be any connection between farming and another source of income with which it is combined to create a chief source of income. ...

In connection therewith, it is noteworthy to draw the attention of the Court to the fact that under section 3 of the Interpretation Act relating to the Rules of Construction there is no exclusion to the Dewey Decimal Classification and Relative Index System. ... In connection therewith, the Respondent never introduced an Expert Witness to corroborate and support the Respondent's allegations and as such the Respondent's objections lack judicial substance. ... In this connection, the Appellant alleges that for each of the years 1985 and 1986 Forms T540-E and T541-E as issued by Revenue Canada, Taxation were correctly printed and embodied the provisions contained in the Income Tax Act, i.e., the exemplification, realization and concretization of those provisions without any exceptions whatsoever. ...

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. ... This exception is very narrow and is available only where there is no connection or link to the employment relationship (footnotes omitted). ...

As noted above, in the discussion of the Status-One decisions, a court must exercise caution when the Crown seeks to include the actions of third parties in the pleadings. [22] Where the actions of third parties are alleged, the relevance or irrelevance of those allegations should be assessed in light of the pleadings. [23] Furthermore, it is incumbent upon the Minister to specify the link between the actions of the third parties and the actions of the specific taxpayer. [24] [66] There is nothing in any of the three Replies that suggests a connection, let alone a specific link, between a particular Appellant and the other wine donors. ... I have not found anything in the Ebert Reply that explains a connection between the 2001 and 2004 transactions and the donations of wine that are the subject of Mr. ... Ebert in respect of the 2005 through 2013 taxation years; (b) specifies a real and substantial nexus or connection between the transactions in 2001 and 2004 and the donations of wines in 2005 through 2013; and (c) does not invoke propensity reasoning. [32] I. ...

The Cadet’s experience and functions on board the ship in connection with his internship are of a nature that clearly connects them with the meaning given to employment in the case law that applies here. [66] In Charron, [23] Justice Archambault noted that the use of the term “scholarship” is not conclusive in determining the nature of the money paid. [67] In light of that case, the fact that the appellants’ witness, Mr. ... He received daily compensation in connection with this participation in the training days he attended, where he performed assigned tasks. ... According to the Cambridge English dictionary, a trainee is “a person who is learning and practising the skills of a particular job”, with the following examples: ” a trainee dentist/electrician”. [77] The appellants seem to conclude, from the meaning given to “intern” for the purposes of the Federal labour standards for interns and student interns and the Federally regulated employer obligations towards interns and student interns in connection with the Canada Labour Code, [25] that when an individual is considered to be an intern, they may not be considered to be an employee and therefore may not be covered by the Act. [78] The result is that if we rely on that interpretation, paragraph 6(b) of the Regulations would never, or very rarely, apply. ...

However, the evidence failed to show the kind of rational connection required by the case law between the risks of the business and the size of the reserves to justify treating the reserves of cash and investments as an integral asset of an active business. ... The arithmetic is extremely straight-forward and I summarize it below: $4.1 million:that is the value of the assets in CCM in the lead up to the sale of the shares to Wiegers.This includes the aforementioned cash, investments and loans to Kanmar; $2.05 million i.e. half of the $4.1 million: that is the value of assets held by CCM that must be used in an active business. $1.37 million: that is what CRA agrees is the value of active assets in the business.It consists almost wholly ($1.32 million) of the of goodwill of CCM and the value of the Royalty Wells.The operating bank account, the accounts receivable, and some miscellaneous assets comprise the rest of the $1.37 million. $710,000.That is the magic number.It is the value of additional assets needed to get from $1.37 million to the $2.05 million or 50% active assets mark. [20] The appellants say that such a connection did exist. ... The case law requires a rational connection between the reasonably determined risk and the amount of the reserves. ...

We undertake to promptly notify our custodian of your authority to act on our behalf in connection with our investment portfolio under your supervision.   3.     ... Perigee will advise the above custodian by written communication of all security transactions in connection with the management of these funds and securities undertaken by Perigee.   ... The Association shall advise MBL in writing from time to time of the name of the representatives of the Association from whom MBL will take instructions in connection with the Portfolio (the “Authorized Representative(s)”).   5.         ...

But the acquisition itself of the shares of those subsidiaries which were to keep carrying on their own businesses, can only be regarded as a pure investment. … the legal expenses here in question … were outlays associated with an "investment transaction", they were made in connection with the acquisition of a capital asset. ... “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.” [39] While one cannot go so far as to say that the Act expressly states that an eligible capital expenditure is one made in respect of a business, the context of those provisions is sufficiently different, in my view, as to warrant more latitude to indirect connections between an expenditure and income from a business than might be the case in respect of the application of paragraph 18(1)(a). ...