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Second, there must be a sufficiently direct connection between the use of the borrowed funds and the source of income. ...

The appellant was relieved from a liability to pay $702,467 in connection with the sale of the said property and the taxpayer was enriched by this amount. ...

Counsel for the Respondent also referred the witness to the following clauses of the agreement: 2.1 Subject as hereinafter provided, First City will lend or arrange to lend to R- 104 amounts required from time to time to fund Project Costs. 2.2 R-104 will pay interest from the date of the advance on all amounts advanced in respect of the Loan and outstanding and on overdue interest thereon at the rate of 2% per annum over the Prime Rate Factor (“Prime Rate Factor” defined in the Debenture). 3.2 At each time Statements are to be delivered to First City pursuant to the provisions hereof, and after the repayment of the Loan, R-104 shall pay to First City on account of the Additional Payment, one-half (1/2) of the Net Cash Flow from the Units or the Lands or the Project, the sales proceeds of which are or are required to be reflected in the Statements then delivered or required to be delivered to First City. and Counsel for the Respondent relied more particularly on sub-clause 7-1(4): (4) expend all drawdowns under the Loan for no purpose other than in connection with the acquisition of the Lands and the construction and completion of the Project and in accordance with the plans and specifications and change orders of the Project approved by First City; Again, the witness saw nothing unusual in these clauses and only the lender’s interest to protect its advances. ...

Both of the latter terms include the phrase “ qualified activities". “ Qualified activities” is defined to mean, inter alia... all other activities that are performed in Canada directly in connection with manufacturing or processing (not including the activities listed in subparagraphs 125.1 (3)(b)(i) to (ix) of the Act) in Canada of goods for sale or lease... ...

The Home Carrier shall also be responsible for billing its customers for, and remitting to, the Federal Government all federal excise tax that may be due in connection with the service being billed by it to its customers. ...

For example, certain administrative activities-- such as the collection of amounts by a bank in connection with a loan which was issued by the bank and the mailing out of monthly statements by that bank-- cannot really be separated from the service of providing the loan itself. ...

.: The issue in this appeal is whether the Appellant, in computing its income under the Income Tax Act (the Act) for the 1990 taxation year, was entitled to deduct an amount of $26,089,145 as a writedown of deposits on land for development, including preliminary development costs expended in connection therewith. ...

In consideration of the return of the said funds and promissory note to me, I hereby release the four general partners from any liability to me in connection with the partnership. ...

  (1)        Notwithstanding paragraphs 18(1)(a), (b) and (h), in computing a taxpayer’s income for a taxation year from a business or property, 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:   …   (p) Bad debts – the total of               (i)         all debts owing to the taxpayer that are established by the taxpayer to have become bad debts in the year and that have been included in computing the taxpayer’s income for the year or a preceding taxation year; and   Minister’s Position   [10]          In reassessing the Appellant, the Minister disallowed a bad debt deduction under subparagraph 20(1)(p)(i) on the basis that the loss in connection with the promissory note was capital in nature [3]. ...

Generally, a person who is experienced in business and financial matters is likely to be held to a higher standard than a person with no business acumen or experience whose presence on the board of directors reflects nothing more, for example, than a family connection. ...