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And then he continues: In this regard, the first issue to be considered is the casual connection requirement... ... When such a connection is present, proprietary relief may be appropriate. ... And continuing at page 249 he states: In addition to the casual connection requirement, it is often suggested that the reasonable expectation of the claimant in obtaining an actual interest in the property as opposed to monetary relief constitutes another important consideration in determining if the constructive trust remedy is appropriate. ...

The table summarizing these amounts, filed in evidence as Exhibit A-4, showed a total paid in this connection from 1983 to 1989 of $9,574.02. ... Rioux in connection with salaries paid to employees. However, I draw a negative conclusion from the absence of any testimony by Mr. ... In this connection I would refer to the Federal Court of Appeal judgment in Friedberg v. ...

The Minister queries whether the expenses of a property were maintained by the taxpayer for the use of the taxpayer and not maintained in connection with a business carried on for profit or with a reasonable expectation of profit. If the property was not maintained in connection with a business carried on for profit or with a reasonable expectation of profit then the Act, at subsection 248(1), provides that the expenses of that property are personal or living expenses; personal or living expenses are not deductible by a tax payable in computing income: paragraph 18(l)(/i). ... See also s. 139(1)(ae) of the Income Tax Act which includes as “personal and living expenses” and therefore not deductible for tax purposes, the expenses of properties maintained by the taxpayer for his own use and benefit, and not maintained in connection with a business carried on for profit or with a reasonable expectation of profit. ...

These shares were acquired and held by the Appellant in connection with its business. ... The sale or disposition of property that is not inventory gives rise to a capital gain or capital loss under the capital gain provisions of the Act (capital property that is depreciable under the Act may also give rise to recapture or a terminal loss). [21] The Appellant has not put forward any relevant exception or other reason to depart from these generally applicable rules for the characterisation of property acquired, manufactured or held in connection with the business. ... That is consistent with the ASF. [22] When the Respondent walked the Court through the above jurisprudence on characterisation of property held in connection with a business, the Appellant offered no reply. [23] The Appellant’s position, simply put by it in its Notice of Appeal, is that the shares were an integral part of its business strategy to enter into contracts to earn business income. ...

For Patricia Agnes Myers the years under appeal are 1986, 1988 and 1989 and there are two issues: the deductibility of expenses which the Appellant contends were business expenses relating to certain costs alleged to have been incurred in connection with a business said to be carried on by the corporation, and capital cost allowance on office furniture and software. ... He sent out letters to many, many people throughout Canada, but this was in connection with the company’s business, not his business. ... Myers can deduct the cost of developing this program for the use of the company in connection with its sales campaign, nor, indeed, do I think the property falls within Class 29. ...

In this context, the words “in respect of” imply a connection between the loss of employment and the subsequent payment, whose primary purpose was compensation for the loss of employment. The two questions to be answered in order to determine whether such a connection exists for the purposes of establishing the existence of a retiring allowance are as follows:   1.       ...

Consequently, it is the activity that resulted in the charges and its connection to the business that determine the deductibility of the legal expenses associated with the defence ... This has no bearing on my decision other than the connection between his law practise and the subject expenses ...

He said that he was driven to Guelph one day a month to visit one of the properties and that he put in 12-hour days in this connection. ... Further, absent any rational connection between the expenditure on the fees and the process of earning income from investments in the two properties, section 67 also applies to prohibit the deductions. ...

And in this case it is clear from the briefs and memoranda filed in connection with the infringement actions that the appellant was claiming compensation for either its own lost profits or an accounting of the profits earned by Flexi-Coil. [43]     It is true that the damages suffered by a patent holder may in a particular circumstance go beyond lost profits. ... In this case, the most important evidence is the appellant's brief and memoranda filed in connection with the infringement litigation, excerpts from which are set out above. ...

Bélec all the slips received from financial institutions in connection with her other investment income. ... It is true that she received tax slips in connection with her other investments. ...