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It is the benefit and advantage of the good name, reputation, and connection of a business. ... Goulet’s task was [translation] “to estimate the fair market value of the portion of goodwill paid by Chemcraft Sadolin inc. on July 31, 2002, which was attributable to [LCR’s] activities”. [18] Although there is a connection, that was not directly the issue to be determined in this dispute. ...

Anthony Vitrano (“Vitrano”), a Florida resident was the sole shareholder of Gameday Connection, Inc. ... When one considers Hill’s testimony that he expressed concerns funds being transferred to iTransit might affect the ability of the Appellant to conduct its contracted obligations, it seems clear there was no connection between these payments and invoices. ...

These appeals raise a number of issues, including: (i) as regards the 1990 taxation year, whether GPL incurred a $259,776 business investment loss in connection with a bad debt; (ii) as regards the 1991 taxation year, whether GPL incurred a $646,487 capital loss in connection with certain investments (advances and shares); (iii) as regards the 1992 taxation year, whether GPL owes interest and penalties on deficient tax instalments; and (iv) as regards the assessment of June 2, 1995, under section 160 of the Act, the fair market value of the property (Montbeillard land) transferred by SIM to GPL on August 8, 1991 (appraisal date) and the amount of SIM’s tax liability. [2] On the last point, the Minister argued that the fair market value of the land was $5,700,000, while GPL argued that the land was worth $4,035,000. ...

Thus, all advances received from Seagull Pewter and Jonathan Bond were repaid within one year from the end of the taxation year of each corporation in which such advances were received. [11] The Appellants argue that the right of setoff arises when there is a mutuality of parties and a connection between the claims made by each. [2] This right was described by Middleton J. as follows: [3] There is, however, another equity which has sometimes been called ‘set-off’ but which does not in any way depend upon the statute, which arises when the claims are upon the same contract or are so interwoven by the dealings between the parties that the Court can find there has been established a mutual credit, or an agreement, express or implied, that the claims should be set one against the other. ... Without such connection, an equity to set-off will not necessarily be granted, an intention to liquidate a debt by the other would have to be found (see s. 130, Canadian Encyclopaedic Digest (Western) 3rd edition, Debtor and Creditor). ...

This is less than a strong nexus but more than a mere possibility or a connection with an extreme degree of remoteness. ...   [74]         The phrase “in contemplation of” in subsection 248(10) allows either prospective or retrospective connection of a related transaction to a common law series. ...

The Appellant has failed to establish any connection between these expenses and the Barcrest sale. ... M.N.R., 85 DTC 455. [27]             85 DTC 272 at 274. [28]             96 DTC 1686 at 1689. [29]             Paragraph 54(g)(iii)- Income Tax Act. [30]             Exhibit R-16- Appellant’s accountants calculations. [31]             Exhibit R-16- page 2. [32]             Exhibit R-16- page 2. [33]             Exhibit R-7- Letter dated April 27, 1989 from Helson Kogon to the Appellant enclosing statements setting out the amounts received and paid out in connection with the purchase and sale of Barcrest and the Nowak farm. [34]             The Appellant’s testimony with respect to Furlong’s involvement is inconsistent, if not contradictory. ...

If all or substantially all of the distance travelled by the automobiles in the total available days was not in connection with or in the course of the office or employment, then the assessment would stand. ... He kept no logs and other records and his memory was somewhat faulty, but I accept that he used the truck in connection with his work to the extent of 80% of the time. ...

That is, even where the security interest is created to secure an obligation, the administrative practice, in respect of mortgages at least, is that the "sale" of the property in the course of realizing on the security interest breaks the connection between the proceeds of sale and the entitlement of the mortgagor. Breaking the connection between the proceeds and sale and the entitlement of the tax debtor not only means that the requirements of paragraph 317(1)(b) are thereby not met but underlines that they are not a source of funds securing payment of the obligation. ...

The Appellant also argued that the Respondent had admitted both in the Reply and in the Agreed Statement of Facts that the excess amounts were payable. [9]            In connection with the contention that the interest payment was contingent, the Appellant relied on Justice Sharlow's comments in Wawang Forest Products Ltd. v. ... RESPONDENT'S SUBMISSIONS: [28]          Similarly, the Respondent acknowledged that the argument in connection with GAAR can be limited to a "misuse and abuse" analysis. ...

Kellogg Co. of Canada, [1943] S.C.R. 58, which allowed the taxpayer to deduct legal expenses incurred in defending a suit for an injunction against alleged infringement of registered trade marks by using certain words in connection with the sale of its products. ... But they were made with a view to protecting the income earning capacity of the company, since it must be assumed that the loss of the right to the use of the words in connection with its sales would have indirectly resulted in a reduction of its income, not only in the year in which they were incurred, but also in future years as well. [37]          Martland J., then held that the legal expenses which the taxpayer in the Premium Iron Ores Ltd. case had incurred in defending itself to protect income were deductible. [38]          Counsel made a reference to the cases of British Columbia Power Corporation Limited v. ...