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31 March 1995 Internal T.I. 9503330- INDIANS-- CONNECTION OF INCOME TO RESERVE Unedited CRA Tags 81(1)(a) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... Although the employee's residence would not be a factor which connects the Indian's employment income to the reserve, it is appropriate under the circumstances laid out in Guideline 4 to recognize a connection since the employee is working for the benefit of Indians on reserve. However, if the population served by the organization was not comprised almost entirely of Indians who live on reserve, this latter connection would not exist. ...

30 May 2005 Internal T.I. 2005-0130431I7- Internet Connection Fees Unedited CRA Tags 18(1)(a) 9(1) Principal Issues: Whether a self-employed person who uses a computer for both business and personal use can claim a reasonable portion of internet connection fees as a business expense. ... Sue Sohnle Charles Rafuse Client Services Division 613-957-8967 2005-013043 Internet Connection Fees This is in reply to your email of May 12, 2005, concerning internet connection fees. ... Expenditures for internet connection fees at a home office will likely contain varying degrees of personal and business elements. ...

2 May 1991 Internal T.I. 9030807 F- Payments in Connection with the Financing of a Company's Operation Unedited CRA Tags 18(1)(a), 12(1)(a), 20(1)(e), 20(1)(f)(ii)   May 2, 1991   Belleville District Office               Rulings Directorate J.E. ... M.N.R., [1949] S.C.R. 287 [49 DTC 514], where it was held that commission payments were not allowable as deductible expenses since they were incurred in connection with the financing of the business and were not related to the income earning process. ... Broadhurst's summary in the 1989 Conference Report ("Income Tax Treatment of Foreign Exchange Forward Contracts, Swaps and Other Hedging Transactions" p. 26:13): The case law in Canada has consistently regarded payments made in connection with the financing of a company's operation as being on capital account unless the taxpayer is engaged in a money-lending business.  ...

Insufficiency of Mere Human Connection Paragraph 5 of Article V of the Convention is a deeming rule which, with certain exceptions, deems a person acting in Canada on behalf of a U.S. resident to be a permanent establishment in Canada if such person has, and habitually exercises in Canada, an authority to conclude contracts in the name of the U.S. resident. ... The facts of the case are that a Swedish company was hired as a consultant for an estimated time of 15 months in connection with the hook-up of a drilling platform on the Norwegian continental shelf. ... However, it is necessary to gather additional facts in order to establish a connection between contracts of short duration (e.g. 2 months) in order to demonstrate that they, together with all other contracts, comprise business conducted in Canada through a permanent establishment. ...

Connections between 6(1)(a), 15(1) and 246(1) 39. No court has concluded on how to determine the value of a taxable benefit under subsection 246(1). ... However, as mentioned in the “Connections between 6(1)(a), 15(1) and 246(1)” section, case law that deals with the notion of “value of a benefit” under paragraph 6(1)(a) and subsection 15(1) can be used to determine the value of a benefit by virtue of subsection 246(1). ...

Distance travelled which is not personal in nature (in relation to the employer's business) is considered to be in connection with or in the course of employment; other distance travelled is not. 2&3.     While the activity of engaging in an employment-related telephone call on a mobile phone may constitute an activity that is in connection with employment, it does not follow that the distance travelled by the automobile while the driver is so engaged is also in connection with or in the course of employment. 4&5.      ... In summary, it is our position that personal travel as described in paragraph 5 of IT-63R3 cannot be converted to travel 'in connection with or in the course of employment' by the concurrent use of a mobile phone for employment purposes. ...

They import such meanings as "in relation to", "with reference to" or "in connection with". ... Therefore services provided by a foreign affiliate to a taxpayer in connection with either a guarantee or a warrantee associated with a product sold by the taxpayer would not qualify for the exclusion under paragraph 95(3)(b) as having been performed in connection with the sale of goods. ... The Queen, 83 DTC 5041 (SCC), you have submitted that the words "in connection with", found in paragraph 95(3)(b), convey only some connection between two related subject matters, not necessarily a direct connection". ...

What are to be considered activities that would be carried on in Canada in connection with the exploration or exploitation of the seabed and subsoil and their natural resources ("in connection with the offshore resources")? ... Transportation activities (e.g. ferrying of supplies and personnel) in connection with the offshore resources fall within paragraph 2 of Article XXVIIA. ... The wording "in respect of an employment exercised aboard a tugboat or similar vessel in connection with such activities" as used in paragraph 5(b) is unclear. ...

Reasons: It had been our view that the phrase "debts incurred in connection with the purchase and sale of investments" should be interpreted strictly. ... In a memorandum to you dated June 30, 2005, we discussed the meaning of the phrase "debts incurred in connection with the purchase and sale of investments" in paragraphs 149.1(3)(d) and (4)(d) of the Income Tax Act. ... Jurisprudence has confirmed that the phrase "in connection with" has a very broad meaning (see the Supreme Court of Canada commentary in that regard in Nowegijick v. ...

Concerning the "connection standard", Canadian case law, albeit not specifically dealing with the interpretation of paragraph XXIX-A(3), suggests that the expression "in connection with" has a broad connotation, although not as wide as the expression "in respect of". We are of the view that in order for an item of income to meet the "connection standard", there should be a strong connection between it and the US active trade or business. ... The last two assertions rely on an interpretation of the "connection standard" that allows it to be met based on either a "use test" or a "funding approach". ...