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As stated in paragraphs 5 and 6 of Interpretation Bulletin IT-143R2, entitled "Meaning of Eligible Capital Expenditure", the courts have referred to several definitions of goodwill, two of which are: (a) "Goodwill is the whole advantage, whatever it may be, of the reputation and connection of the firm which may have been built up by years of honest work or gained by lavish expenditures of money." (b) It is "the privilege, granted by the seller of a business to the purchaser, of trading as his recognized successor; the possession of a ready-formed "connection" of customers, considered as an element in the saleable value of a business, additional to the value of the plant, stock-in-trade, book debts etc. ...

The Taxpayer has, for more than six consecutive months, performed all or substantially all of his employment duties in Poland in connection with a contract under which Canadaco carries on business in Poland with respect to engineering activities. ... That provision provides that the taxpayer must perform all or substantially all of his duties of employment, either in connection with a contract under which the specified employer carried on business outside Canada or for the purpose of obtaining on behalf of the specified employer a contract for any of the activities specified in subparagraph 122.3(1)(b)(i). ...

Please note that Guideline 4 requires a) that the employer is resident on a reserve; b) that 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 c) that the duties of the 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. ... The employment duties of XXXXXXXXXX employees would also have to be considered to determine if, as required under Guideline 4, they were 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. ...

In the scenarios described in your letter, it is our view that the departmental position set out in paragraph 17 of IT-531 described above may also apply in connection with such direct transfer of excess funds from an EFA for an individual to another EFA for another individual. ... As we doubt that, from a policy perspective, the beneficial treatment set out in paragraph 17 of IT-531 should apply in connection with a direct transfer from an EFA of an individual to another EFA of another individual, we have referred the matter to the Department of Finance for their consideration. ...

This is comparable to our position on other postgraduate programs pursued while employed and the student is reimbursed for tuition fees, or the tuition is paid directly by the employer 2)tuition tax credit requirements seem to have been met, however since residents are in receipt of employment income in connection with their residency they would not be eligible for the education tax credit (see E920906 and 961018) 962055 XXXXXXXXXX D. ... This definition specifically excludes a program of study which is taken in connection with or as part of the duties of the student's employment and the student is receiving compensation for that employment. ...

In this connection, we note that "active business carried on by a corporation" means any business carried on by the corporation other than a specified investment business or a personal services business. ... Thus, the corporation, which provides no more than normally expected utility connections and minor other services, would appear to be a "specified investment business" rather than an active business. ...

In connection with the level of skills and knowledge required, you have mentioned that the employer provides the pilot with numerous manuals which the pilot is expected to update and maintain. ... There are a number of requirements that must be satisfied before an employee is entitled to deduct certain types of maintenance costs in connection with workspace in the home. ...

In connection with the above situation, it is our understanding, pursuant to our telephone conversation, that Holdco would have a legal obligation to pay the premiums related to the two individuals it employs and that Opco would have a legal obligation to pay the premiums in respect of the individuals that it employs. ... Other than the comments concerning a plan that is restricted to an employee/shareholder and his or her spouse, the comments made in connection with the first situation are relevant in respect of this situation. ...

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. ...

If the Workers are in fact employees of Dco, they would not qualify on the basis that they would not be considered to be employed in connection with a contract under which Dco carries on business outside Canada with respect to qualifying activities. ... Even if Dco did have certain contracts under which it carried on business outside Canada with respect to a qualifying activity, it is unlikely that substantially all the Workers' duties associated with the installation of a computer system designed to enhance Dco's general business operations could be viewed as having been performed in connection with such contracts. ...