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The Appellant added that he was awaiting the introduction of Ontario legislation which would permit the water and sewer connections to be made by connecting with the existing system in the house. ... The Appellant had read about it and thought that that was the most expedient way to proceed, i.e., to wait for legislation which would enable him to make such a connection direct from the house to the shop. ... It was the Appellant's contention that until this bill was adopted he could not have made the connections from the house, although that fact was not definitely proved. ...

The agreement provided that any and all disputes, claims or controversies of any nature arising out of or in connection therewith, should be dealt with in accordance with the laws of the State of Virginia, and settled by arbitration under the auspices of the American Arbitration Association. ... Whether Northside benefited is not the issue in this appeal, and even if it did so benefit, that does not preclude a finding that the appellant also received a benefit under the Act (see Doyle, supra). [24] According to counsel for the respondent, there is no connection between the legal fees incurred and the appellant's position with Northside. ... In that regard, I disagree with counsel for the respondent that there was no connection between the legal expenses incurred and the business operations of Northside. [34] The cases referred to by counsel for the respondent are not relevant. ...

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. ... Snow had few residential connections to Canada at this point and ceased to be a Canadian resident at that time. [17]         In that particular case, the Appellant had relied upon Perlman v. ... Her connection with her society was through her husband and her husband’s family. [22]         In terms of property and investments, she had no property or investments in Canada, nor business interests, nor any cultural or social interests in Canada, nor did she have a family home in Canada. ...

Kandiah the GST/HST New Housing Rebate (the “Rebate”) of $24,000 in connection with the purchase of 50 Minerva Avenue in Toronto. ... No one appeared certain of when events in connection with the plumbing problem actually occurred. [6]              Mr. ... Kandiah had no right in connection with conveyance. [33]         Further, in the case of Rochefort, evidence of the unusual circumstances was sufficient for me to conclude on balance that Mrs. ...

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 … (f)           Sales expenses- where the taxpayer was employed in the year in connection with the selling of property or negotiating of contracts for the taxpayer’s employer, and (i)      under the contract of employment was required to pay the taxpayer’s own expenses, (ii)     was ordinarily required to carry on the duties of the employment away from the employer’s place of business, (iii)    was remunerated in whole or part by commissions or other similar amounts fixed by reference to the volume of the sales made or the contracts negotiated, and (iv)    was not in receipt of an allowance for travel expenses in respect of the taxation year that was, by virtue of subparagraph 6(1)(b)(v), not included in computing the taxpayer’s income, amounts expended by the taxpayer in the year for the purpose of earning the income from the employment (not exceeding the commissions or other similar amounts referred to in subparagraph 8(1)(f)(iii) and received by the taxpayer in the year) to the extent that those amounts were not (v)     outlays, losses or replacements of capital or payments on account of capital, except as described in paragraph 8(1)(j), (vi)    outlays or expenses that would, by virtue of paragraph 18(1)(l), not be deductible in computing the taxpayer’s income for the year if the employment were a business carried on by the taxpayer, or (vii)   amounts the payment of which reduced the amount that would otherwise be included in computing the taxpayer’s income for the year because of paragraph 6(1)(e); … (h)          Travel expenses- where the taxpayer, in the year, (i)      was ordinarily required to carry on the duties of the office or employment away from the employer’s place of business or in different places, and (ii)     was required under the contract of employment to pay the travel expenses incurred by the taxpayer in the performance of the duties of the office or employment, amounts expended by the taxpayer in the year (other than motor vehicle expenses) for travelling in the course of the office or employment, except where the taxpayer (iii)    received an allowance for travel expenses that was, because of subparagraph 6(1)(b)(v), 6(1)(b)(vi) or 6(1)(b)(vii), not included in computing the taxpayer’s income for the year, or (iv)    claims a deduction for the year under paragraph 8(1)(e), 8(1)(f) or 8(1)(g);             … 8(4)      Meals.   ... 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 … (f)           Sales expenses- where the taxpayer was employed in the year in connection with the selling of property or negotiating of contracts for the taxpayer’s employer, and (i)      under the contract of employment was required to pay the taxpayer’s own expenses, … (h)                      Travel expenses- where the taxpayer, in the year, … (ii)     was required under the contract of employment to pay the travel expenses incurred by the taxpayer in the performance of the duties of the office or employment, … [28]         To be eligible for a deduction under either subparagraph, the appellant must show that he was "required" by his contract of employment to pay his own sales expenses and travel expenses incurred by him in conjunction with his employment, and for which he is not entitled to reimbursement from his employer. [29]         There is a distinction in being permitted to do something and being required to do something as noted by Bowie J. in Morgan v Canada, 2007 TCC 475, 2007 DTC 1360, at paragraph 12. [30]         Absent an express requirement in a written contract, if it is tacitly understood by the employer and employee that such payment was to be made and necessary to fulfill the duties, that would suffice. [31]         In his testimony, the appellant said that there was no written contract. ... Commission fixed by reference to sales volumes or contracts negotiated [36]         As previously noted, under subparagraph 8(1)(f)(iii), an employee may deduct sales expenses but the employee must be employed in the year in connection with selling property or negotiating contracts for his employer, and be remunerated wholly or partially by commissions or similar amounts fixed by the volume of sales made or contracts negotiated. [37]         In Griesbach v. ...

However, the minister disallowed some ITCs claimed in connection with two suppliers, namely P.F.G. ... This amount is related to ITCs claimed in connection with supplies purportedly received from P.F.G.; [2]   −                    denied an amount of $325,248.89 of ITCs in connection with supplies purportedly received from Operatech. [3] This amount remains in dispute.   4. ...

In other work, it must only be determined whether there is a reasonable connection between the bonus incentives and the prosecution of the SR&ED.   ...   [36]         The Appellant’s written submissions are instructive in the present appeal but they do not address the only relevant issue: is there a reasonable connection between the bonus incentives and the prosecution of the SR&ED? ...   [41]         I am of the opinion that there is no connection with the payment of the bonuses at issue and the bonus policy followed in the past by Old Dataradio, with any SR&ED work carried on during the year at issue. ...

They contacted a builder, a connection through Mr. Sekhon’s family, to help with that permit application. ... 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 the opening of an office or advertising) there is some evidence of dealing in the property.   5.         ... iv)     Work expended on or in connection with the property   [22]         Little work was expended on the property directly by the Appellants. ...

  [3]              In this case, the Respondent’s principal position is that the amounts were fellowships described in subparagraph 56(1)(n), but that they did not qualify for the scholarship exemption in subparagraphs 56(1)(n)(ii) and 56(3)(a)(i) because they were not received in connection with Mr. ... n) l'excédent éventuel:   (i) du total des sommes (à l'exclusion des […] sommes reçues dans le cours des activités d'une entreprise et des sommes reçues au titre, dans l'occupation ou en vertu d'une charge ou d'un emploi) reçues au cours de l'année par le contribuable à titre de bourse d'études, de bourse de perfectionnement (fellowship) ou de récompense  couronnant une oeuvre remarquable réalisée dans son domaine d'activité habituel, à l'exclusion d'une récompense visée par règlement,   sur:   (ii) the taxpayer's scholarship exemption for the year computed under subsection (3); […] […]   (ii) l'exemption pour bourses d'études du contribuable pour l'année, calculée selon le paragraphe (3); […] […] Exemption for scholarships, fellowships, bursaries and prizes     56.(3) For the purpose of subparagraph (1)(n)(ii), a taxpayer's scholarship exemption for a taxation year is the total of   Exemption pour bourses d'études, bourses de perfectionnement (fellowships) ou récompenses   56.(3) Pour l'application du sous-alinéa (1)n)(ii), l'exemption pour bourses d'études d'un contribuable pour une année d'imposition correspond au total des sommes suivantes:   a) the total of all amounts each of which is the amount included under subparagraph (1)(n)(i) in computing the taxpayer's income for the taxation year in respect of a scholarship, fellowship or bursary received in connection with the taxpayer's enrolment   a) le total des sommes représentant chacune la somme incluse en application du sous-alinéa (1)n)(i) dans le calcul du revenu du contribuable pour l'année au titre d'une bourse d'études ou d'une bourse de perfectionnement (fellowship) reçue relativement à son inscription:   (i) in an educational program in respect of which an amount may be deducted under subsection 118.6(2) in computing the taxpayer's tax payable under this Part for the taxation year, for the immediately preceding taxation year or for the following taxation year, or […]   (i) soit à un programme d'études pour lequel une somme est déductible en application du paragraphe 118.6(2)dans le calcul de l'impôt à payer par le contribuable en vertu de la présente partie pour l'année, pour l'année d'imposition précédente ou pour l'année d'imposition subséquente, […]   (c) the lesser of $500 and the amount by which the total described in subparagraph (1)(n)(i) for the taxation year exceeds the total of the amounts determined under paragraphs (a) and (b).   ...   [12]         A taxpayer’s scholarship exemption for a year is the total of all amounts received by the taxpayer in the year as or on account of fellowships and similar amounts that were received in connection with his enrolment in an educational program that qualifies for the subsection 118.6(2) education credit ...

Was it necessary for the appellants to own the subject land in connection with their business use? ... I shall, however, consider briefly the question as to whether the appellants used the subject land in connection with a farming business. ... In my view, these appeals must be dismissed because the appellants did not use the subject land in connection with any business, and they did not own it during the period when they might have used it for business purposes. ...