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Generally, legal fees are deductible where they are incurred in connection with normal activities, transactions or contracts incidental or necessary to the earning of income from a business or property. In the circumstances described, the legal fees were incurred in connection to the lawsuit filed against the shareholder on the premise there was fraud and breach of fiduciary duty and in our view, do not represent a deductible current expense to the shareholder. ...

Reasons: Where an employee is reimbursed for actual expenses incurred in connection with the duties of employment and the amount is nominal, the amount is generally not a taxable benefit. ... However, where an employee is reimbursed for actual expenses incurred in connection with the duties of employment and the amount is nominal, the amount is generally not a taxable benefit. ...

Principal Issues: Whether the payment by an employer of external consulting fees in connection with an employee-pay-all plan will taint the status of the plan Position: It may if the fees relate to premiums to the plan Reasons: In accordance with our IT 428, to qualify as an employee-pay-all plan, the employees must be legally obligated to pay 100% premiums. ... You have posed numerous questions concerning various situations whereunder the employer pays external consulting fees in connection with an employee-pay-all plan. ...

In order to qualify for the OETC under subsection 122.3(1) of the Act, an individual resident in Canada must, throughout any period of more than 6 consecutive months, have performed all or substantially all the duties of employment outside Canada in connection with a contract under which the specified employer carried on business outside Canada with respect to any construction, installation, agricultural or engineering activity, or with respect to the exploration for minerals, to mention the main ones. ... XXXXXXXXXX In order to qualify, all or substantially all (90%) of the duties of the flight crew members' employment would have to be in connection with contracts for qualified activities. ...

However, for this purpose the Department considers the word "lodge" to mean an inn or resort hotel, particularly one that is a centre for recreational activities, as well a dwelling occupied on a seasonal basis in connection with particular activities, such as hunting or fishing. ... However, as stated in response to question 15 of the Revenue Canada Round Table held at the 1984 Conference of the Canadian Tax Foundation, the Department considers the word "lodge", for this purpose, to mean an inn or resort hotel, particularly one that is a centre for recreational activities, as well a dwelling occupied on a seasonal basis in connection with particular activities, such as hunting or fishing. ...

Furthermore, it is our view that the term "in connection with television" as used in subsection 212(5) is very broad and would apply to videotapes destined for private home use. ... Income Tax Convention; the said payments representing copyright royalties in respect of the reproduction of any literary, dramatic, musical or artistic work other than in respect of motion pictures and works on film, videotape or other means of reproduction for use in connection with television broadcasting. ...

Still question of fact if meets second requirement for exemption that not in connection with a rental or franchise agreement. ... It remains a question of fact whether or not the information is being provided in connection with a rental or franchise agreement. ...

Reasons: Payments must be only for use of type of information described, and information cannot be provided in connection with a rental or franchise agreement. ... The relevant agreements would have to be examined to ensure that the payments are for the use of such information, that they are solely for such purpose, and that the information is not being provided in connection with a rental or franchise agreement. ...

Beginning in 2003, where the personal use of the automobile is less than 1,667 kilometres per month and the automobile is used primarily in connection with or in the course of the office or employment, the standby charge is reduced. Prior to 2003, in order to reduce the standby charge, the personal use of the vehicle had to be less than 1,000 kilometres per month, and all or substantially all of the use- generally at least 90%- had to be in connection with or in the course of the office or employment. ...

A taxpayer using the cash method to compute income from a farming business may elect to transfer inventory owned in connection with the business, to a corporation under subsection 85(1) of the Act. ... Generally, where a taxpayer or partnership carrying on a farming business transfers, using section 85, inventory owned in connection with that business to a corporation, and the taxpayer or partnership reports income from the farming business on the cash basis, paragraph 85(1)(c.2) of the Act will apply to ensure that the taxpayer includes the deemed proceeds of disposition in income, under subparagraph 28(1)(a)(i) of the Act, and that the corporation will be entitled to deduct the deemed cost of the inventory under subparagraph 28(1)(e)(i) of the Act. ...