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He respectfully submits that the Minister properly reassessed the Appellant for the Period in respect of the back-charges as the Appellant over claimed ITC's in amount of $153,648.88 in connection with the back-charges pursuant to the provisions of sections 165, 168, 169, 221, 222 and 225 of the Act. 19.      ... He respectfully submits that the Minister properly reassessed the Appellant for the Period in respect of the back-charges as the Appellant collected as or on account of tax in connection with the back-charges the amount of $153,648.88 and failed to remit the amount so collected as required by sections 222, 225 and 228 or, in the alternative, as the Appellant over claimed ITC's in amount of $153,648.88 in connection with the back-charges pursuant to the provisions of sections 165, 168, 169, 221, 222 and 225 of the Act. 19.      ...

Simek outside Canada in connection with the Yakutsk airport terminal project included negotiating the contract, purchasing materials from Russian and Slovak suppliers, making design changes, assisting the Yakutian government in obtaining funding for the project, attending conferences and collecting payments. ... His evidence showed that he traveled extensively in connection with the two Yakutsk contracts in 1995, not only to that city, but to places in Europe, Asia and North America as well. ... He also said that travel between Yellowknife and Yakutsk could take between 48 and 64 hours depending on flight connections. [11]     The only other evidence of actual hours worked outside Canada related to a trip Mr. ...

Those reassessments disallowed their claims to deduct from their other income the losses sustained by them in connection with a rental property that they owned jointly at that time. ... The appeals of Oscar Aragon and Nelia Aragon for the 1993 and 1994 taxation years will therefore be allowed, and the reassessments will be referred back to the Minister of National Revenue for reconsideration and reassessment on the basis that the Appellants are entitled to deduct their losses incurred in connection with their rental property in the computation of their incomes for those years. [2]            The Appellants own and operate Carnel, a company that carries on the business of bookkeeping and accounting. ... The appeals of Oscar Aragon and Nelia Aragon for 1993 and 1994 are allowed and the assessments are referred back to the Minister for reconsideration and reassessment on the basis that they are entitled to take into account their losses in connection with the rental property in the computation of their incomes. [13]          Since the Respondent did not consent to judgment in respect of the rental losses claimed by Oscar Aragon and Nelia Aragon until the day of the hearing, and since Nelia Aragon and Roderic Aragon are successful in respect of the penalty issue, the parties shall each bear their own costs. ...

The notice of assessment is numbered 0319915. [2]      The case concerns the input tax credit claim made in connection with the invoices of Alvaro Jimenez or Confection Alvaro Jimenez for the period from July 1996 to May 21, 1999. [3]      When the hearing began, counsel for the respondent amended the Reply to the Notice of Appeal to include the amounts involved in the above-mentioned reassessment. [4]      The appellant's witnesses were Michael Khouri, Brian Stott and Hélène Bellerose. ... I find it surprising that the appellant's computer program did not require the inclusion of a registration number in connection with the supplier's name and address when a tax amount was paid on the supplier's invoices. [34]     In my view, it is not a relevant argument in this case to say that, had the appellant known in May 1999 that the number was not valid from the beginning, that is, since July 1996, it could have asserted its rights with the supplier differently. [35]     This is not really a case about information to be provided by the tax authorities to the recipient of a service or good. ... It is dismissed with respect to the input tax credit claim in connection to the supplier Confection Alvaro Jimenez. ...

The Appellant paid the remaining 65% of the amount entered in the Record of Employment to third parties to finance two loans in connection with the acquisition of two vehicles, one of them in the name of Sonia Gagnon and the Appellant, the other in the name of the Worker, Harold Milligan ...   [11]     Thirty‑five percent of the compensation showing in the Record of Employment was paid in full through a subsidy issued by Emploi‑Québec, pursuant to an undertaking in connection with a work‑integration contract ... The Fonds d'emprunt communautaire de la Gaspésie et des Îles has chosen to make payments in connection with the purchase and maintenance of Mr.  ...

The rental losses arise in connection with the property in which Ms. Jarquio resided and which she rented to several family members. [2]            The Appellant acquired the property in question at 111 Fishery Road in Scarborough, Ontario in May 1997 jointly with her sister Pilar Jarquio at a cost of $163,000.00. ... The first is to rely on the statutory reasonable expectation of profit test as set forth in paragraph 18(1)(h) and the definition of personal or living expenses in section 248 of the Act, which reads as follows: "personal or living expenses" includes (a)            the expenses of properties maintained by any person for the use or benefit of the taxpayer or any person connected with the taxpayer by blood relationship, marriage or adoption, and not maintained in connection with a business carried on for profit or with a reasonable expectation of profit,... ... The Act, by defining "personal or living expenses" as it has, requires a finding that the activity generating income from property must constitute a business to avoid this definition. [15]          Therefore in connection with the disallowed expenses the Appellant must show either: 1.              ...

For the cost of insurance to be a deductible business expense, there must be some reasonable, factual connection between the carrying on of the business and the payment of the premiums. ... The connection between benefiting the Appellant or her husband and the insurance costs is far too tenuous. ... As in the insurance claim, the connection to earning income is too remote. [12]          With regard to the remaining expenses, I agree with the Minister’s position set out in Schedule "A" attached hereto. ...

In that year, the Appellant deducted the aggregate amount of $5,039 as a medical expense in connection with her attendance at a weight loss clinic. ... In that connection, I again refer to the relevant words in paragraph 118.4(2)(a) which state: 118.4(2)                   For the purposes of sections... 118.2..., a reference to..., medical practitioner,... is a reference to a person authorized to practise as such (a)           ..., pursuant to the laws of the jurisdiction in which the service is rendered; [9]            The above would apply to all the other professions such as nurse, occupational therapist, optometrist, pharmacist or psychologist. ... They were apparently purchased by the Appellant at the Clinic in connection with her counselling with this woman Shaine Kanji-Lalani, and basically sold to the Appellant like any other product. ...

(a) was employed by a person who was a specified employer, other than for the performance of services under a prescribed international development assistance program of the Government of Canada, and (b) performed all or substantially all the duties of the individual's employment outside Canada (i) in connection with a contract under which the specified employer carried on business outside Canada with respect to (A) the exploration for or exploitation of petroleum, natural gas, minerals or other similar resources, (B) any construction, installation, agricultural or engineering activity, or (C) any prescribed activity, or (ii) for the purpose of obtaining, on behalf of the specified employer, a contract to undertake any of the activities referred to in clause (i)(A), (B) or (C), there may be deducted, from the amount that would, but for this section, be the individual's tax payable under this Part for the year, an amount equal to that proportion of the tax otherwise payable under this Part for the year by the individual that the lesser of (c) an amount equal to that proportion of $80,000 that the number of days (i) in that portion of the qualifying period that is in the year, and (ii) on which the individual was resident in Canada is of 365, and (d) 80% of the individual's income for the year from that employment that is reasonably attributable to duties performed on the days referred to in paragraph (c) is of (e) the amount, if any, by which (i) where section 114 is not applicable to the individual in respect of the year, the total of the individual's income for the year and the amount, if any, included pursuant to subsection 110.4(2) in computing the individual's taxable income for the year, and (ii) where section 114 applies to the individual in respect of the year, the total of (A) the individual's income for the period or periods in the year referred to in paragraph 114(a), and (B) the amount that would be determined under paragraph 114(b) in respect of the individual for the year if subsection 115(1) were read without reference to paragraphs 115(1)(d) to (f) exceeds (iii) the total of all amounts each of which is an amount deducted by the individual under section 110.6 or paragraph 111(1)(b) or deductible by the individual under paragraph 110(1)(d.2), (d.3), (f) or (j) for the year or in respect of the period or periods referred to in subparagraph (ii), as the case may be. ... Assuming the other requirements of subsection 122.3(1) are met, the employees of A Ltd. providing the data processing services would qualify for the OETC, since their employment is in connection with a contract under which the specified employer carried on business outside Canada with respect to qualifying activities. [23] All that was required is that Wheeler Canada provided services in connection with a contract under which Wheeler Canada carried on business outside Canada with respect to qualifying activities. [24] Wheeler Canada was a sub-contractor in the Kuwait project and carried on its engineering business in Kuwait by providing engineering services to the main contractor of the project. [25] For these reasons, the appeal is allowed and the assessment is referred back to the Minister of National Revenue for reconsideration and reassessment on the basis that the Appellant is entitled to the Overseas Employment Tax Credit as provided for in subsection 122.3(1) of the Act. [26] Counsel wished to make submissions concerning costs. ...

All or substantially all of the travel using the Truck was in connection with purposes related to the business of the Company, including, but not limited to, the following: (a)            taking daily deposits to the Royal Bank in either Wapella or Moosomin; (b)            picking up food and supplies at least once per week from either Regina or Yorkton;                 (c)            picking up liquor supplies and returning bottles. 15.            ... The Respondent has erred in assessing the Appellant regarding the Truck in that she failed to consider that: (a)            the Appellant was required by the Company to use the Truck in the course of his employment; (b)            all or substantially all of the distance traveled by the Truck was in connection with or in the course of the Appellant's employment; (c)            the Appellant owns a 1993 Buick automobile which he used for his personal driving needs. [11]          The Appellant, for the first six months of 1994, lived with his wife at least part-time in a cottage in White Bear and drove approximately 60 kilometers from time to time to work in Whitewood. ... 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. ...