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In the interim, Motiuk stated she received requests for information and applications for social insurance numbers or UI benefits which, although some of them might have been farm labourers, had no connection to her regular duties or to the function of the AES office. ... The necessary computer program was operated by the Regional Informatics Branch- a creation of the federal government- and AES staff received training on that system in Edmonton and all expenses in connection with attendance for that purpose were paid, even if a local operating budget had to be amended and more money supplied by HRDC in a forthcoming monthly cheque to cover those costs. ... This is particularly true when the person has no prior employment connection with the party who benefits from his services. ...

The matter of ties within the jurisdiction asserting residence and elsewhere runs the gamut of an individual's connections and commitments: property and investment, employment, family, business, cultural and social are examples, again not purporting to be exhaustive. ... There the             question is whether that person has become "ordinarily resident" in Canada; (c) cases where a Canadian resident leaves Canada and severs his           or her connection with this country so that he or she is not a     Canadian resident, and then reacquires ties here. ... This is shown by the various factors, which have already been related which indicated that he still had substantial connections to Canada. [115]        In essence counsel argued that on the totality of evidence, the Appellant's presence in the U.S. in the years in question was temporary and his ties to Canada, albeit not as deep-rooted as one would expect if somebody resided in Canada for 15 or 20 years, since he was a recent immigrant from Nigeria to Canada, indicate that his intention was to come back to Canada. [116]        There are a number of references in the evidence to correspondence between the Appellant and the C.C.R.A., where he expressly stated that he would be returning to Canada upon the conclusion of his program and at the end of the day he did return to Canada. ...

In connection with the matters described in subparagraphs (a) through (i), the Association has paid or incurred legal fees of approximately $1,500,000. 39. ... The cost of the annual education seminars is covered by a grant received from the Alberta Government. [4]           Neither party called any witnesses nor produced any further documents in evidence. [5]           Counsel for the appellants submitted the issue to be decided is as follows: Whether the amounts paid by the appellants to the Alberta Provincial Judges' Association are membership dues in an association of public servants the primary purpose of which is to promote the improvement of its members' conditions of employment or work pursuant to subparagraph 8(1)(i))iv) of the Act. [6]           Although pleaded- in the alternative- in each Notice of Appeal filed on behalf of each appellant, submission on the issue of deductibility of membership dues pursuant to paragraph 8(1)(b) of the Act- on the basis there was a connection between payment of Association dues and the establishment of a right to salary or wages owed to each appellant- and to all other judges of the Provincial Court of Alberta- was abandoned by counsel for the appellants. [7]      The relevant portions of subparagraph 8(1)(i)(iv) of the Act read as follows: 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:...    ... It would have been extremely difficult to consider the total amount of the membership fee and to somehow attribute an appropriate portion thereof directly to each member's pro rata cost of the global litigation which, inter alia, produced the salary reimbursement as opposed to allocations in respect of other Association activities, such as costs incurred in connection with conferences and meetings having other purposes. [40]     The assessment(s) of the Minister- as they apply to each appellant- are valid. ...

Without limiting the generality of the foregoing, the Assets include:               (i)         the Sites and Buildings;               (ii)        the Equipment;               (iii)       the Land Rights;               (iv)       the Current Assets;   (v)        the full benefit of the Contracts and all other contracts or commitments to which the Vendor or TransAlta Utilities Corporation or any of their Affiliates is entitled in connection with the Business including, without limiting the generality of the foregoing, all forward commitments of the Vendor or TransAlta Utilities Corporation or any of their Affiliates for supplies or materials entered into in the usual and ordinary course of Business whether or not there are any written contracts with respect thereto, but excluding, for clarity, contracts or commitments of a general nature that do not Primarily relate to the Business;   (vi)       the Warranties, if any;   (vii)      the Permits;   (viii)      computer software listed in Schedule 1.1(a);   (ix)       the goodwill of the Business including, without limiting the generality of the foregoing,   A.        ... It is the benefit and advantage of the good name, reputation, and connection of a business. ... The only real possible benefit was in connection with the one partner, Ontario Teachers Pension Plan Board, who may not have had to pay tax. ...

In addition, in later years the Conservatory Group provided mortgages to third-party purchasers in connection with its real estate business and invested large amounts of surplus funds in commercial paper ... It submits that the loan was made in connection with its overall profit-making scheme and was of a class of loan arrangement usually entered into by it. ... The exception carved out of these denial provisions permits the intercorporate dividend deduction in connection with term preferred shares acquired outside the “ordinary course of [the] business” carried on by the taxpayer ...

Krmpotic because of his connection to the numbered company. Precondition (3) has been met because the payment would have been for the benefit of Mrs. ...   [121]   Counsel argued that the Minister seemed to be thinking that the fact that these properties were written down somehow had a connection to the disposition of the property but the dates are completely different. ... Krmpotic was only in December of 2000 so there was no connection between the two. ...

Any claim for salary in connection with meetings away, other than the Confederation office or council must include a pay stub from the week in which the actual loss of salary occurred.     ... Expenses incurred in connection with activities held during a vacation period or on weekday programmed leave shall be reimbursed to the union member even if time is made up for.   ...   [57] In my opinion, this result is entirely in keeping with the situation of numerous volunteers who work for various charitable organizations and who render their services without being remunerated but are compensated for the expenses incurred in connection with the activities of these organizations, whether they be for profit or not. ...

Furthermore, the connection between the appellants and the Reserve is mitigated by the fact that the employment relationships between the appellants and NLS or OI were created merely for the purpose of obtaining a paragraph 87(1)(b) exemption. ... In Monias, the Federal Court of Appeal attached almost no significance to the location of branches of the banks from which the employer paid salaries and at which the employees’ accounts were credited, saying (at paragraph 57):   Where employees receive their employment income has little, if any, logical connection with the policy underlying section 87 ...   [146]      In the absence of any special circumstances that would tie the appellants’ work to a specific reserve, and in the absence of evidence of a significant connection between their work and the Six Nations Reserve or any other reserve, there is no basis for concluding that the taxation of their employment income from NLS or OI would result in the erosion of their entitlement to property they held as Indians on a reserve ...

NM I's proportionate share of revenues was subject to a further annual adjustment based on the cumulative expenditures made by NM I and Vidatron in connection with the marketing program. ... NM II's proportionate share of revenues was subject to a further annual adjustment based on the cumulative expenditures made by NM II and Vidatron in connection with the marketing program. ... Jones said that she provided no instructions to Grant in connection with his evaluation preparation and that Grant had come to her telling her what he needed in order to do so. ...

Colbran's attention so that he is fully aware of the steps being taken by the Landlord. [18]     He then produced a letter from Murray Holmes to 95 stating that he had searched their files and could not find any record of having acted for the Appellant in connection with the Cheesecake Café. [19]     The Appellant produced a copy of a letter dated March 29, 2000 to Tillyard & Partners, Inc. from The Cheesecake Cafe not bearing a signature but bearing the typed name of R.F. ... It is noted that Beeson appeared as the Respondent's only witness, having appeared as the result of being served with a subpoena so to do. [111] It is clear, from the evidence of both the Appellant and Beeson, that the Appellant was employed by the Beeson group to perform operational services in connection with the Victoria Cheesecake Café. [112] I accept the Appellant's evidence that when he signed the subscription for shares of 95 and signed the CONSENT TO ACT AS A DIRECTOR, he expressly directed Ross, the lawyer who produced the "shelf" company not to use those documents until he had become a resident of British Columbia and until other conditions specified by him were fulfilled. ... In that company Wheeliker signed statements of particulars in connection with a Royal Bank of Canada account as "director" and the Agreement Re: Operation of Account as "director" of the company. ...