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Kaplan has strong connections in Canada, but these do not translate to a daily settled routine of life and customary mode of living in Canada. [45]         Given his family ties in Canada, I accept that Mr. ... Kaplan in anticipation of the review of residency status by the CRA, as he was fully aware of the importance of establishing connections to Canada for the Benefit. [49]         As for religious affiliations in Canada, while the evidence was vague, I am satisfied that he had at least one religious affiliation as he had indicated on the 2006 NR73 form. ... Overall, an analysis of personal and economic ties shows more connections to the U.S. [53]         Mr. ...

The distinction was pointed out by Davies J in connection with similar words used in s.26AAA(4) of the Act in Barnsdall v. ... The Commissioner is required to be satisfied not merely of a connection between a taxpayer and the person to whom the taxpayer transferred, but also of the fact that they were not dealing with each other at arm's length. A finding as to a connection between the parties is simply a step in the course of reasoning and will not be determinative unless it leads to the ultimate conclusion. ...

.; (i)                    Pied-Mont Dora Inc. is the owner of the trademarks used in connection with the above-mentioned flavour crystals; (j)                    Net income generated by the appellant’s crystals business was $185,184, $147,249 and $121,102 for taxation years 1991, 1992 and 1993 respectively; (k)                  Net losses incurred in the racehorse business and claimed by the appellant were $160,750, $70,522 and $193,229 for taxation years 1991, 1992 and 1993 respectively; (l)                    The appellant deducted the losses suffered in the racehorse business from the income generated by the sale of crystals; (m)                 The operation of the appellant’s racehorse business from July 1, 1989 to December 31, 1993 never generated any profits; rather it generated operating losses of about $651,195; (n)                  In the years at issue, the appellant’s chief source of income was neither a farming activity nor a combination of farming and some other source. [7] In his Reply the Respondent however added paragraphs 18 and 19 as follows: [TRANSLATION] 18. ... I quote from pages 486 to 489: There has been difference of opinion on whether the word “combination” in s. 13(1) requires some “connection” by way of physical relationship or integration or inter-connection between farming and the subordinate activity which provides another source of income.... ...

‘Tangibles’ [5] means all of the Vendor’s right, title, estate and interest in and to all tangible depreciable property and assets (except casing) situate in, on or about the Lands, appurtenant thereto or used in connection therewith and with production operations thereon including, but not in limitation of the generality of the foregoing, appurtenant to or used in connection with all producing or shut-in wells located on the Lands.” 15 January 1986 (D) Lone Rock and all of its shareholders enter into a share purchase agreement with the appellant whereby the latter acquired all of the shares of Lone Rock. ... Subparagraph 66(15)(c)(iii) reads: “(iii) any oil or gas well in Canada or any real property in Canada the principal value of which depends upon its petroleum or natural gas content (but not including any depreciable property used or to be used in connection with the extraction or removal of petroleum or natural gas therefrom).” 29 September 1986 (E) Lone Rock as transferor and the appellant as transferee enter into a “Distribution Agreement” whereby Lone Rock “assigns, transfers and conveys to and sets over unto the transferee all of the right, title and interest of the transferor in and to all its property, assets and business”. ...

Accordingly, a deduction cannot be so far removed from its corresponding income stream as to render its connection to the anticipated income tenuous at best. ... The determination of whether there is sufficient connection between the taxpayer and the income earning potential of the debtor will be decided on a case by case basis depending on the particular circumstances involved. [48]     According to that decision, the lender taxpayer need not derive income directly from the loan because taxpayers sometimes grant interest-free loans, expecting that the activities financed by those loans will produce income. ... The question as to whether there is a sufficient connection between the debt and the taxpayer's income is decided on a case-by-case basis on the facts of each case. [49]     In this instance, the nature of cooperatives must be considered. ...

This vehicle was owned by the Company, and all the expenses in connection with it were covered by the Company. ... Don Servais pursuant to section 15 in connection with the Ford Enforcer, based on including 100% of the operating costs, insurance, loan payments and GST. ... Don Servais pursuant to section 15 in connection with the 1992 Ford truck and trailer based on including 100% of the principal and interest payments made for the truck and trailer. ...

., the Appellant's sister's company, for loss of profits in connection with the project;                                 iv)            a defamation action against the Appellant brought by his brother-in-law; and                                 v)             a claim by an investor for damages arising out of a refusal to sign a joint venture agreement. [13]          With the exception of the defamation action, these proceedings were brought against all the members of the Partnership, and the Partnership paid the legal bills. ... His oral evidence was that much, if not all, of those cheques, as well as many internal bank transfers, went to satisfy the cash requirements of the Partnership. [21]          The Appellant also testified that his line of credit, which was paid off at least twice, once with proceeds of the second mortgage and once with proceeds of the third mortgage, had been used to fund the various studies required in connection with the development project. ... The Appellant testified that Aurora Financial was a corporation owned by him which he used in connection with this development project. ...

In essence, their argument is that there is an inherent historical and traditional connection between their reserves and their fishing activities such that they should be tax exempt even if they are commercial fishing activities. ... At trial, the taxpayers advanced the argument that one of the significant connecting factors which should be given great weight was the tradition of fishing as a way of life among B.C. coastal Indians, its intimate connection with the reserves and with the bands’ traditional way of life. ...   [18]          On appeal to the Federal Court of Appeal, the Native Indian Brotherhood sought to intervene and to file historical documents regarding an alleged connection between reserve allotments to coastal Indian bands and fishing activities of those bands. ...

This is not surprising in connection with the Canadian returns as they were not as computer-friendly in many respects as the U.S. returns. ... Even if I found Home Depot somehow did not act with due diligence in tracking the uncashed cheque, which I do not (as the only evidence I have in that regard is that the practice was to monitor such items), I find there is too remote a connection between that “failure” and the clerical error. I conclude that the level of due diligence exercised in connection with the second error is sufficient to relieve Home Depot of any penalty.   ...

(d)     was the consulting fee the only consideration/remuneration received in connection with the services Mr. ... (g)     were the fees of Wise, Blackman or a portion thereof incurred in connection with the disposition of capital property? ... (o)     were the fees of Wise, Blackman or a portion thereof incurred in connection with the disposition of capital property? ...