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Furthermore, the courts have also stated that connections that are artificial should not be given weight in determining the location of income for purposes of the exemption. ... Connections that are artificial or abusive should not be given weight in the analysis... ... The various connections between the Reserve and the Appellants' income from fishing are indisputably bona fide and not motivated by tax avoidance considerations. ...

Furthermore, the courts have also stated that connections that are artificial should not be given weight in determining the location of income for purposes of the exemption. ... Connections that are artificial or abusive should not be given weight in the analysis... ... The various connections between the Reserve and the Appellants' income from fishing are indisputably bona fide and not motivated by tax avoidance considerations. ...

However, the "true connection" which he did find is a virtual connection with "each and every reserve in Canada" based on the exceptionally beneficial nature of the services rendered by the respondent through his employment and his genuineness qua Indian (see paragraph 5, supra). ... Specifically, it cannot be said that the taxation of the respondent's income would result in the erosion of his entitlement qua Indian on any or all of these reserves as there is no connection whatsoever between this income as such and these reserves as economic bases or physical locations (Monias, supra, paragraphs 46 and 67). ...

However, the "true connection" which he did find is a virtual connection with "each and every reserve in Canada" based on the exceptionally beneficial nature of the services rendered by the respondent through his employment and his genuineness qua Indian (see paragraph 5, supra). ... Specifically, it cannot be said that the taxation of the respondent's income would result in the erosion of his entitlement qua Indian on any or all of these reserves as there is no connection whatsoever between this income as such and these reserves as economic bases or physical locations (Monias, supra, paragraphs 46 and 67). ...

Paragraph 6(1)(b) of the Act A reasonable per-kilometre allowance received by an employee for the use of his or her personal motor vehicle in connection with the duties of employment is generally excluded from employment income by virtue of paragraph 6(1)(b) of the Act. Subparagraph 6(1)(b)(vii.1) of the Act, for example, excludes "reasonable allowances for the use of a motor vehicle received by an employee (other than an employee employed in connection with the selling of property or the negotiating of contracts for the employer) from the employer for travelling in the performance of the duties of the office or employment". ... Flat-Rate and Combined Allowances For purposes of paragraph 6(1)(b) of the Act, a motor vehicle allowance is deemed not to be a reasonable when the measurement of the use of the motor vehicle for the purpose of the allowance is not based solely on the number of kilometres for which the vehicle is used in connection with the duties of employment [subparagraph 6(1)(b)(x)]. ...

An RCA is defined in the Canadian Income Tax Act (the "Act") as "a plan or arrangement under which contributions... are made by an employer or former employer of a taxpayer... in connection with benefits that are to be or may be received or enjoyed by any person on, after or in contemplation of any substantial change in the services rendered by the taxpayer, the retirement of the taxpayer or the loss of office or employment of the taxpayer... ... A resident's contribution includes a contribution that can reasonably be considered to have been made in respect of services rendered by an individual to an employer in a period throughout which the individual was resident in Canada and rendered services to the employer that were primarily services rendered in Canada or services rendered in connection with a business carried on by the employer in Canada or a combination of such services. ... In general, a prescribed contribution is a contribution made after 1991 to a foreign plan where the employer elects to report pension adjustments in connection with the participation of the employees in the foreign plan and certain other conditions are satisfied. ...

Subsection 212(5) of the Act indicates that a Canadian withholding tax of 25% applies namely to a payment for a right in or to the use of a motion picture film, or a film, video tape or other means of reproduction for use in connection with television, provided that they are used or reproduced in Canada and only to the extent that this payment relates to that use or reproduction. ... However, this exemption does not apply to payments in respect of motion pictures or of works on film, videotape or other means of reproduction for use in connection with television broadcasting. ... You have indicated to us that, based on the definitions of “broadcasting” and “radio or radiocommunication” under subsection 35(1) of the Interpretation Act, you do not consider streamed TV shows to be “in connection with television broadcasting” since they are not “propagated in space without artificial guide” and, as such, you believe that the royalty payments to the U.K. ...

The costs in connection with attending or organizing a convention or a business meeting can receive different tax treatment from the costs of attending or organizing a training course. ... Thus, for U.S. income tax purposes an individual who is a citizen or resident of the United States and who attends a convention held in Canada may claim deductions for expenses incurred in connection with such convention without regard to the provisions of Code section 274(h). Section 274(h) imposes special restrictions on the deductibility of expenses incurred in connection with foreign conventions. ...

In the circumstances where an employer ceases to carry on a part of its business operation and, in respect of a settlement payable to the union, pays an amount to the union which, in turn, makes payments in connection with the settlement to the employees whose jobs were terminated, it seems to us, as explained below, that the above comments on distributions by a union are not relevant because the ultimate source of the payments is the employer. ... They import such meanings as "in relation to", "with reference to" or "in connection with". The phrase "in respect of" is probably the widest of any expression intended to convey some connection between two related subject matters. ...

For the purposes of paragraph (1)(e), a reasonable standby charge for an automobile for the aggregate number of days (in this subsection referred to as the "total available days") in a taxation year during which the automobile is made available to a taxpayer or to a person related to the taxpayer by the employer of the taxpayer or by a person related to the employer (both of whom are in this subsection referred to as the "employer") shall be deemed to be the amount determined by the formula A 2- x (2% x (C x D) +- x (E- F)) B 3 where A is the lesser of (a)     the aggregate 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 total available days, and (b)     the value determined for B for the year under this subsection in respect of the standby charge for the automobile during the total available days, except that the amount determined under paragraph (a) shall be deemed to be equal to the amount determined under paragraph (b) unless (c)     the taxpayer is required by the employer to use the automobile in connection with or in the course of the office or employment, and (d)     all or substantially all of the distance travelled by the automobile in the total available days is in connection with or in the course of the office or employment; B is the product obtained when 1,000 is multiplied by the quotient obtained by dividing the total available days by 30 and, if the quotient so obtained is not a whole number and exceeds one, by rounding it to the nearest whole number or, where that quotient is equidistant from two consecutive whole numbers, by rounding it to the lower thereof; C is the cost of the automobile to the employer where the employer owns the vehicle at any time in the year; D is the number obtained by dividing such of the total available days as are days when the employer owns the automobile by 30 and, if the quotient so obtained is not a whole number and exceeds one, by rounding it to the nearest whole number or, where that quotient is equidistant from two consecutive whole numbers, by rounding it to the lower thereof; E is the aggregate of all amounts that may reasonably be regarded as having been payable by the employer to a lessor for the purpose of leasing the automobile during such of the total available days as are days when the automobile is leased to the employer; and F is the part of the amount determined for E that may reasonably be regarded as having been payable to the lessor in respect of all or part of the cost to the lessor of insuring against (a)     loss of, or damage to, the automobile, or (b)     liability resulting from the use or operation of the automobile. ...