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7 December 2000 External T.I. 2000-0032685- QUALIFIED DISPOSITION SEGREGATED FUNDS-- summary under Subsection 107.4(3) Summary Under Tax Topics- Income Tax Act- 101-110- Section 107.4- Subsection 107.4(3) If a policyholder does not realize any disposition of an interest in a segregated fund contract (viewed as analogous to a capital interest in a trust) by virtue of a variation of the contract that occurs in connection with a qualifying disposition, s. 107.4(3)(k) would apply to add policyholder's cost base in the transferor to its basis, if any, in the transferee trust. Similarly, if a policyholder, in connection with a variation of a contract that occurs in connection with a qualifying disposition, should dispose of an interest in the segregated fund contract, s. 107(3)(j) would provide a rollover to the policyholder. ...

23 May 2001 External T.I. 2001-0077855 F- PLACEMENT ADMISSIBLE REER-- summary under Subsection 4900(8) Summary Under Tax Topics- Income Tax Regulations- Regulation 4900- Subsection 4900(8) did not extend to services rendered in connection with the company’s incorporation A share issued to a person in payment for services rendered in connection with the incorporation of the company was not subject to Regs. 4900(8) and (13), as those provisions refer to an amount received in respect of a share issued. ...

3 May 2002 External T.I. 2001-0110145 F- avantage imposable-vetements-- summary under Paragraph 6(1)(a) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a) reimbursing a professor for a briefcase needed in connection with work would be non-taxable Where a professor is reimbursed by the university for the cost of a briefcase used to carry documents when travelling in connection with work, for example, giving lectures on behalf of the University, CCRA was generally prepared to accept that the payment was made primarily for the benefit of the employer, so that there would be no taxable benefit to the extent the amount was reasonable in the circumstances. ...

CRA stated: Given the breadth of the expression "in connection with" and of the term "property", even if the Incentive Payments were payable as consideration for a service described in any of clauses 212(1)(d)(iii)(A) to (C), they should not be subject to Part XIII withholding tax based on the exception in the post amble to subparagraph 212(1)(d)(iii) since they appear to have been made either for services performed in connection with the sale of property or the negotiation of a contract. ...

11 February 2013 External T.I. 2012-0469441E5 F- Aire de plancher- fabrication et transformation-- summary under Paragraph 1100(1)(a.1) Summary Under Tax Topics- Income Tax Regulations- Regulation 1100- Subsection 1100(1)- Paragraph 1100(1)(a.1) washrooms and cafeteria included- along with office if a connection with the M&P personnel In response to a question as to whether floor space representing a cafeteria, washroom and office qualified, CRA stated (TaxInterpretations translation):... ... Similarly... if the nature of the activities performed in the office has a connection with the personnel engaged in the manufacturing and processing in Canada of goods for sale or lease, then the floor space of the office also qualifies as being used for the manufacturing or processing in Canada of goods for sale or lease. ...

3 December 2004 External T.I. 2004-0089341E5 F- Intérêts et frais juridiques-- summary under Legal and other Professional Fees Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Legal and other Professional Fees legal fees to recovery a legacy were non-deductible In finding that fees of lawyers and experts incurred by the taxpayer, in in connection with bringing an action to recover a legacy payable pursuant to a codicil to a will, were non-deductible, CRA stated: [T]he taxpayer did not incur them for the purpose of earning business or property income since she incurred those fees of lawyers and experts to recover amounts owed to her in connection with a family inheritance. ...

29 August 2001 External T.I. 2001-0097485 F- DEDUCTION DE FRAIS DE SURVEILLANCE-- summary under Paragraph 20(1)(bb) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(bb) supervisory fees paid to intermediary between portfolio manager and taxpayer were non-deductible Regarding the deductibility pursuant to s. 20(1)(bb) of fees paid by a taxpayer to a portfolio supervisor, CCRA stated: Where the principal activity of a taxpayer is to act as an intermediary between taxpayers and their portfolio managers, we are of the view that the person does not appear to be offering services in connection with the administration or management of shares or securities but rather in connection with advisory and recommendation services with respect to the manager. ...

23 January 2020 External T.I. 2019-0796121E5 F- Déduction pour résidence des membres du clergé-- summary under Paragraph 8(1)(c) Summary Under Tax Topics- Income Tax Act- Section 8- Subsection 8(1)- Paragraph 8(1)(c) s. 8(1)(c) does not entail any home office requirement Is a regular minister, in addition to meeting the other conditions set out in IT-141R, required to maintain an office in the taxpayer's residence or use it in connection with the taxpayer’s duties as a member of the clergy in order to qualify for the clergy residence deduction? CRA responded: [P]aragraph 8(1)(c) does not require that the taxpayer in question maintain an office in the taxpayer's residence or use it in connection with the taxpayer’s duties as a member of the clergy in order to qualify for the clergy residence deduction. ...

31 May 2004 External T.I. 2004-0069681E5 F- Adjusted Cost Base of Real Property-- summary under Adjusted Cost Base Summary Under Tax Topics- Income Tax Act- Section 54- Adjusted Cost Base legal fees and settlement payment made in connection with disputed legacy of residence might be an addition to its ACB Although Mr. ... B that was incurred in connection with the acquisition of the Residence. … It is … possible that, through [the] transfer contract, Mr. ... B that would have been incurred in direct connection with the acquisition of the Residence would be added to Mr. ...

In the course of general comments, CRA stated: [T]he words "in respect of" [in s. 248(1) – "retiring allowance"] have been held… to imply a connection between the loss of employment and the subsequent receipt, where the primary purpose of the receipt was compensation for the loss of employment. Two questions set out by the Courts to determine whether a connection exists for purposes of a retiring allowance are as follows: But for the loss of employment would the amount have been received? ...