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However, in Bedford, the Supreme Court found that there was a “sufficient causal connection” between the impugned Criminal Code provisions and the prostitutes’ security of the person. The Court held that these provisions imposed dangerous conditions on prostitution. [21]         In the case before me, it has not been shown that there is a sufficient causal connection between paragraph 118.2(2)(n) of the Act and Ms. ...

As a result I am left with no clear picture of the expenses actually incurred by him in connection with these properties. If they have been overstated by him, and as a result the losses are exaggerated, then he is the author of his own misfortune, because I have concluded, at least in part on the basis of the long and unbroken string of very large losses claimed by him, that the Appellant could have had no reasonable expectation of profit in connection with these properties, and that he consequently had no business, and no source of income therefrom. [9] Mr. ...

Krueger. [13]No connection was established between any specific amount of employment income received by the Appelant and time spent by him at his home. ... However the connection between time spent in the home receiving those calls and the receipt of employment income is, at best, tenuous. ...

" personal or living expenses "- "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. [24]     In Tonn v. ... He added that Moldowan, supra, has been utilized in regular commercial type situations and that the facts of each case will determine whether the activity is to be considered a business activity. [26]     The appeals in question relate to the appellant's activities in 1997 and 1998 in connection with his property. ...

Effective October 1, 1996, was HSBC Holdings BV legally obligated to indemnify HSBC Holdings plc, against all actions, claims, demands, liabilities, losses, damages, costs, charges and expenses of whatever nature which HSBC Holdings plc might sustain, suffer or incur in connection with HSBC Holdings plc’s guarantee of the deposit liabilities of the Appellant and the Appellant’s subsidiaries?   ... The parties do not, I suggest, need a Motion’s Judge to interpret the contracts, especially without the context of all the surrounding facts in connection with the creation of the contracts, or to assist experts, or to establish some paradigm or to assist the parties compile an agreed statement of facts or joint book of documents. ...

(a)                Did the Minister properly include $66,000 in the appellant’s income as self-employment income received in connection with a real estate project?   ...   [8]               The securities breaches relate to over $1,500,000 that was raised from investors in connection with the project. ...

Doshi’s Amended Notice of Appeal are improper.   12)               Pursuant to Section 128.1(4), CRA has asked me to pay $28,713 in capital gains for Tax Year 1999, and $18,404 of arrears interest, in connection with the Applicable Securities.   13)               In a speech delivered to Parliament on March 27, 2001, Roy Cullen, who was Parliamentary Secretary to Finance Minister Paul Martin, described Bill C-22, which proposed to modify the Income Tax Act in various ways.  ... It modified, inter alia, Sections 7(1.6) and 220 of the Income Tax Act.   15)               On February 4, 2003, I received a letter from CRA showing my foreign tax credit for capital gains income tax paid to the U.S. government in connection with the Applicable Securities.   19)               Ms. ...

These payments were an allowance and were includable under paragraph 6(1)(b) of the Income Tax Act unless the amounts were reasonable. [35]             However, because the amounts were not based solely on the number of kilometres for which the vehicles were used in connection with or in the course of the office or employment are deemed not to be reasonable under paragraph 6(1) (b) (vii.1) and (x). [36]             Therefore, the amounts are taxable, insurable and pensionable. [37]             In Arnett & Burgess Oil Field Construction Ltd. above, the Court concluded that the presumption was a rebuttable one. ... Therefore the per diem paid to the owners was properly classified as “an allowance” under paragraph 6(1) (b) of the Income Tax Act. [56]             Further, the Court is satisfied that the allowance was not based solely on the number of kilometres for which the vehicle was used in connection with or in the course of the office or employment of the workers and under subparagraph 6(1) (b) (x) it is deemed not to be a reasonable allowance. [57]             In the case of Tri-Bec Inc. v. ...

(emphasis added) 6. (1) Amounts to be included as income from office or employment-- There shall be included in computing the income of a taxpayer for a taxation year as income from an office or employment such of the following amounts as are applicable: (e) standby charge for automobile-- where the taxpayer's employer or a person related to the employer made an automobile available to the taxpayer, or to a person related to the taxpayer, in the year, the amount, if any, by which (i) an amount that is a reasonable standby charge for the automobile for the total number of days in the year during which it was made so available exceeds (ii) the total of all amounts, each of which is an amount (other than an expense related to the operation of the automobile) paid in the year to the employer or the person related to the employer by the taxpayer or the person related to the taxpayer for the use of the automobile; 6. (1)(k) automobile operating expense benefit-- where (i) an amount is determined under subparagraph (e)(i) in respect of an automobile in computing the taxpayer's income for the year, (ii) amounts related to the operation (otherwise than in connection with or in the course of the taxpayer's office or employment) of the automobile for the period or periods in the year during which the automobile was made available to the taxpayer or a person related to the taxpayer are paid or payable by the taxpayer's employer or a person related to the taxpayer's employer (each of whom is in this paragraph referred to as the "payor"), and (iii) the total of the amounts so paid or payable is not paid in the year or within 45 days after the end of the year to the payor by the taxpayer or by the person related to the taxpayer, the amount in respect of the operation of the automobile determined by the formula A- B where A is (iv) where the automobile is used primarily in the performance of the duties of the taxpayer's office or employment during the period or periods referred to in subparagraph (ii) and the taxpayer notifies the employer in writing before the end of the year of the taxpayer's intention to have this subparagraph apply, 1 / 2 of the amount determined under subparagraph (e)(i) in respect of the automobile in computing the taxpayer's income for the year, and (v) in any other case, the amount equal to the product obtained when the amount prescribed for the year is multiplied by the total number of kilometres that the automobile is driven (otherwise than in connection with or in the course of the taxpayer's office or employment) during the period or periods referred to in subparagraph (ii), and B is the total of all amounts in respect of the operation of the automobile in the year paid in the year or within 45 days after the end of the year to the payor by the taxpayer or by the person related to the taxpayer;   [22]          I conclude from all of the evidence that a benefit was conferred on Babich. ...

  [9]     It seems to me that the explanation lies in Dale and Darren’s connection to the family business. ... She was also of the view that because Darren was the one with shop and management experience and was paid a lower wage, but for the family connection, the company would have been more likely to keep Darren on and lay off Dale ...