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There were considerable costs incurred in connection with the complex litigation described above, principally legal and audit fees. ...

In connection with the launch Kingswood organized an aggressive media blitz. ...

Canada, [1993] 2 C.T.C. 2475. 1 Subparagraph 110(1)(a)(i) and paragraph 110(8)(c) of the Act provide: 110(1) For the purpose of computing the taxable income of a taxpayer for a taxation year, there may be deducted such of the following amounts as are applicable: (a) the aggregate of gifts made by the taxpayer in the year (and in the five immediately preceding taxation years to the extent of the amount thereof that was not deductible in computing the taxable income of the taxpayer for any preceding taxation year) to (i) registered charities, not exceeding 20 per cent of the income of the taxpayer for the year computed without reference to subsection 137(2), if payment of the amounts given is proven by filing receipts with the Minister that contain prescribed information. 110(8) In this section, (c) registered charity” at any time means (i) a charitable organization, private foundation or public foundation, within the meanings assigned by subsection 149.1(1), that is resident in Canada and was either created or established in Canada, or (ii) a branch, section, parish, congregation or other division of an organiza tion or foundation described in subparagraph (i), that is resident in Canada and was either created or established in Canada and that receives donations on its own behalf, that has applied to the Minister in prescribed form for registration and that is at that time registered as a charitable organization, private foundation or public foundation. 2 Subsections 163(2) and (3) provide: 163(2) Every person who, knowingly, or under circumstances amounting to gross negligence in the carrying out of any duty or obligation imposed by or under this Act, has made or has participated in, assented to or acquiesced in the making of, a false statement or omission in a return, form, certificate, statement or answer (in this section referred to as a "return") filed or made in respect of a taxation year as required by or under this Act or a regulation, is liable to a penalty of.... (3) Where, in any appeal under this Act, any penalty assessed by the Minister under this section is in issue, the burden of establishing the facts justifying the assessment of the penalty is on the Minister. 3 Paragraphs 239(1)(d) and (e) and subsection 239(2) of the Act provide: 239(1) Every person who has (d) wilfully, in any manner, evaded or attempted to evade, compliance with this Act or payment of taxes imposed by this Act, or (e) conspired with any person to commit an offence described by paragraphs (a) to (d), is guilty of an offence and, in addition to any penalty otherwise provided, is liable on summary conviction to.... (2) Every person who is charged with an offence described in subsection (1) may, at the election of the Attorney General of Canada, be prosecuted upon indictment and, if convicted, is, in addition to any penalty otherwise provided, liable to imprisonment for a term not exceeding five years and not less than two months. 4 Subsection 220(5) provides: Any officer or servant employed in connection with the administration or enforce ment of this Act, if he is designated by the Minister for the purpose, may, in the course of his employment, administer oaths and take and receive affidavits, decla rations and affirmations for the purposes of or incidental to the administration or enforcement of this Act or regulations made thereunder, and every officer or servant so designated has for such purposes all the powers of a commissioner for administering oaths or taking affidavits. ...

(c) In addition to the requirement that the interest sought to be deducted must be paid or payable pursuant to a legal obligation to pay interest on borrowed money, subparagraph 20(1)(c)(i) of the Income Tax Act further stipulates that such borrowed money must be used for the purpose of earning income from a business or property, and (i) the use of the borrowed money to earn income from a business or property must be direct: a mere causal connection between the use of the money and any benefit ultimately received is insufficient: Canada Safeway Ltd. v. ...

Work expended on or in connection with the property realized. If effort is put into bringing the property into a more marketable condition during the ownership of the taxpayer or if special efforts are made to find or attract purchasers (such as opening of an office or advertising) there is some evidence of dealing in the property. 5. ...

Giglio stated he was aware the lawsuit settlement was the result of an incomplete property transaction but did not know until later that it was specifically in connection with 850 Fort Street. ...

The Court decided that there was a strong connection between the receipt of the benefits and the place where the employment giving rise thereto was located. ...

But was it the company's intention when it paid the severance allowance to provide compensation for the unjust dismissal or was it in connection with previous services?” ...

In this connection counsel referred me to the statement of Ritchie, J. of the Supreme Court of Canada in A. ...

As in Meisels, the Court pointed out that no direct connection could be drawn between these outlays and the earning of business income. ...