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The new legal foundations of the "fiducie" rest upon the civil law concept of patrimoine (estate), and avoid any connection with the common law concept of fiduciary ownership or with the establishment of a trust as a true moral personality. ... We note that the obstacles that Quebec must overcome in connection with common law are basically linked to an interpretation of "fiducie" by persons who only know the concepts of trust, with its resulting dual ownership. ...

The taxpayer appealed and the Federal Court of Appeal agreed with Teskey J. stating at page 6086:... the value of the benefit was not reduced by credit balances in the shareholders loan accounts for the years in question as there was no connection between the loan and the costs incurred in acquiring the property. ... There is no connection between the art and the costs incurred in acquiring the house. ...

We are to be retained today by the Appellant in connection with the above matter, which is set down for hearing in Toronto on January 7, 2003 at 9:30 a.m. ... This is not altered by the fact that he was a realtor. [12]          In the course of the hearing, the Appellant attempted to raise an issue with respect to a loss that he may have suffered in connection with his interest in the Ross Street house. ...

Issue [6]      The question for determination is whether the legal fees of $7,034.24 paid in connection with negotiating a retiring allowance are deductible in computing income. ... Assuras in connection with the notice of objection refers to paragraph 60(o.1) and explains how it is applied in these circumstances. 2           Counsel for Mr. ...

Paragraphs 15, 16, 17, 19 and 20 [9]            These paragraphs allege certain conduct on the part of officers of the Respondent in connection with the investigation that gave rise to the assessment under appeal. ... The affidavit of the Appellant filed in support of her motion does not address any questions of conscience in this connection. ...

In filing his income tax returns for those two years, the Appellant claimed to be entitled under section 3 of the Income Tax Act (the Act) to deduct from his other income, losses incurred in connection with certain real estate which I shall refer to as "the property. ... Kouros for the use of the property during that period of time as he declared gross income of nil in both 1996 and 1997 in connection with the property. ...

Heard maintains the losses of $5,365.00 and $7,029.00 for 1996 and 1997 respectively were incurred in connection with his business of picture framing. ... Part of the write-off related to limited edition prints which had suffered water damage, and part was in connection to obsolete inventory, which was burned. [6]            Throughout the 1990's Mr. ...

She argues that administrative practice permits the credit to a parent supporting a child living away from home while attending school (IT-513R) and that any reading of the Act that permits this accommodation should prevail to permit the credit in this case as well. [10]          Contrary to the Appellant's submission, Interpretation Bulletin IT-513R does not seem to entirely abandon a requirement that the supported child away at school have a live-in connection to the supporting parent's residence. ... While the Bulletin makes the connection between the student and the supporting parent's residence, the notion of where one "ordinarily" lives is laden with interpretative difficulties and goes beyond the language of the section. ...

I find, however, that the standby charge of $5,570.00 was proper and there is no need to amend the Net Worth Assessment in that regard. [7]            In connection with the nature and validity of the Net Worth Assessment, I refer to the decision of Bowman, T.C.J, as he then was, in Ramey v. ... In this connection I refer to the decision of Hamlyn, J. in Campbell v. ...

Minister of National Revenue, 70 DTC 1744 lead to a similar conclusion. [7]            The only legislative provision in connection with support payments that offer some retroactive relief is found in section 60.1(3). ... R., 1999 CarswellNat 562, [1999] 2 C.T.C. 2677, DTC 3502 allowing the deductibility of amounts paid in 1994 and 1995 by a common law husband in connection with a relationship which had ended in 1988. ...