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The Appellant is known as a nonprofit corporation and, specifically, part III of the Letters Patent (Exhibit 1) states the objects to be as follows: III The objects of the Corporation are: (a) to make available insurance plans and similar plans and benefits to members of the legal community in Canada and such other persons as the Board of Directors may determine from time to time, (b) to negotiate and contract with insurance companies with respect to the insurance plans and benefits referred to in (a) above, (C) to supervise the provision to certain persons as determined by the Board of Directors from time to time of pension or retirement funds and plans including registered retirement savings plans and registered retirement income funds; (d) to prepare and distribute informational material relating to the availability of such insurance and registered retirement savings plans and benefits, (e) to provide the administrative services required in connection with the provision and supervision of said insurance and registered retirement savings plans and benefits, and (f) to do all such other things as are incidental or conducive to the attainment of the above objects, In no event shall the purposes of organization and/or operation of the Corporation include profit. ... The Caisse populaire (“CP”) was assessed for business tax under the Ontario Assessment Act with respect to property it occupied in connection with its operations. ...

The exploration activities undertaken by the Appellant and its Predecessor Companies in connection with the Seismic Data have included:            (a)       geological, geophysical and engineering analyses of the Seismic Data to determine potential prospects;            (b)      analysis of land availability;            (c)       farm-out agreements;            (d)      purchase of petroleum and natural gas leases; and            (e)       drilling of wells. 14.       ... The applicant also described the exploration activities undertaken by it and its predecessor corporations in connection with the seismic data.... [26]       The Crown has a serious obligation to set out honestly and fully the actual assumptions upon which the Minister acted in making the assessment, whether they support the assessment or not. ...

They claimed the balance of the Farming Capital Gains Exemption in 2009 in connection with the gain included in income in that year. ... However, subsection 110.6(1.3) of the Act mandates that there be a close connection between the parties in such a case. ...

Under those guidelines, the Euroleases are direct financing leases and CCLI recorded its revenues and expenses in connection with the Euroleases in accordance with the accounting rules for direct financing leases. ... Analysis- Foreign Exchange Issue [24]     The Appellant argues that CCLI was in the financing business, that is, money was its business and, therefore, borrowing money was acquiring inventory; consequently, any foreign exchange gains or losses in connection with that underlying borrowing transaction are on income account. ...

Des Chênes and cases decided by this Court suggest a loose connection between a service and provincial funding will be sufficient to characterize government funding as consideration for that service. ... A vague connection between a requirement to pay and a service performed would not typically constitute consideration applying common law principles. ...

As a result, while the corporate partner will remain a successor indefinitely, if it loses its connection with the resource property it will no longer have income “that may reasonably be regarded as attributable” to property, and its maximum deduction under subparagraph 66.7(10)(j)(ii) would be nil ... It is our view that as long as the connection between two things or actions is easily discernible then the two things or actions could reasonably be considered to be related ...

Deductions   Deductions allowed          8. (1) 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:   Sales expenses   (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 8(1)(f)(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 8(1)(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);   Travel expenses   (h) 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 traveling 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), 6(1)(b)(vi) or 6(1)(b)(vii), not included in computing the taxpayer’s income for the year, or   (iv) claims a deduction for the year under paragraph 8(1)(e), 8(1)(f) or 8(1)(g);     General limitation   (2) Except as permitted by this section, no deductions shall be made in computing a taxpayer’s income for a taxation year from an office or employment.   ...   [26]          The appellant was employed in connection with the selling of information technology for Allstream in the years at issue and was remunerated in part by commissions. ...

He maintained with his spouse two joint bank accounts in Canada, one was used for the mortgage in connection with one of their properties and the other was used for everything else including another mortgage. ... However, the Appellant maintained the Canadian connections with Canada in case he did return. ...

The Queen, [1983] 1 S.C.R. 29, the Supreme Court of Canada held at page 39 of that decision that the words “in respect of” were “words of the widest possible scope” and that the phrase “in respect of” is probably the widest of any expression intended to convey some connection between two related matters. [66]         It is only necessary, then, to show some connection between the B.C. ...

All that was important was a telephone connection with clients and suppliers. ... It is even likely that their lack of connection to the reserve explains, to a large degree, the failure of the Wigwam project. ...