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The courts (footnote 3) have also stated that connections that are artificial should not be given weight in determining if income is situated on a reserve for purposes of the exemption. ...

(b) What are the income tax consequences to a timber tenure holder of its accrued silviculture obligations that are assumed by the Province of British Columbia in connection with a reduction in tenure under the provisions of the FRA? ... (b) Where a timber tenure holder is relieved from the obligation to incur accrued silviculture costs in connection with the reduction in a timber tenure pursuant to the provisions of the FRA, the value of the silviculture obligation from which the timber tenure holder is relieved will be included in its proceeds of disposition of the property or part thereof disposed of. ...

Therefore, if a policyholder does not realize any disposition of an interest in a segregated fund contract by virtue of a variation to that contract that occurs in connection with the qualifying disposition, our view is that paragraph 107.4(3)(k) would apply to add the policyholder's cost base in the transferor to its basis, if any, in the transferee trust. ... Similarly, if a policyholder should realize a disposition of an interest in a segregated fund contract by virtue of a variation to that contract that occurs in connection with the qualifying disposition, our view is that paragraph 107.4(3)(j) would apply to provide a rollover to the policyholder. ...

Canadian Development Expense Subsection 66.2(5) defines CDE exhaustively and such definition does not appear to include the types of expenses that would generally be incurred in connection with the development of a lithium brine reservoir. ... None of the other paragraphs in the definition of CDE would appear to apply to expenses that are likely to be incurred in connection with a lithium brine project. 4. ...

The connection between the expense incurred and the search for what is in the ground has also been highlighted by the Courts. ... R, (footnote 9) the Federal Court of Appeal stated as follows: Furthermore, we would, as a general rule, expect that for any expense to be said to have been incurred for the purpose of determining the existence etc. of petroleum or natural gas on a property, there would have to be at least some connection between that expense and work actually done on the ground. ...

Paragraph 4 of Article XII of the Treaty states: "The term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work (including motion pictures and works on film, videotape or other means of reproduction for use in connection with television), any patent, trade mark, design or model, plan, secret formula or process, or for the use of, or the right to use, tangible personal property or for information concerning industrial, commercial or scientific experience, and, notwithstanding the provisions of Article XIII (Gains), includes gains from the alienation of any intangible property or rights described in this paragraph to the extent that such gains are contingent on the productivity, use or subsequent disposition of such property or rights. ...

; (iii) What actions did the taxpayer take in connection with the reduction in value or increase in cost?” ...

That is, a taxpayer's child includes a person that has an "in-law" relationship with the taxpayer because of a connection by marriage (e.g., son-in-law or daughter-in-law). ...

Specifically, Guideline 4 requires that: o The employer is resident on a reserve; and o The employer is: an Indian band which has a reserve, or a tribal council representing one or more Indian bands which have reserves; or an Indian organization controlled by one or more such bands or tribal councils, if the organization is dedicated exclusively to the social, cultural, educational, or economic development of Indians who for the most part live on reserves; and o The duties of employment are in connection with the employer’s non-commercial activities carried on exclusively for the benefit of Indians who for the most part live on reserves. ...

However, the deduction applies only to tuition assistance and not to other types of assistance a student may receive in connection with the student’s training. ...