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Reasons FOR POSITION TAKEN: The wording of the provision authorizes a reassessment as long it is (1) a consequence of a decision on appeal in respect of a particular previous year, (2) completed within the time frame set out in the provision and (3) there is a reasonable connection to the change in the particular year. ... "related"- have reference to; stand in some relation to "relation"- what one person or thing has to do with another; kind of connection between persons or things. ... It is our view that as long as the connection between two things or actions is easily discernible then the two things or actions could reasonably be considered to be related. ...

That is, there must be a clear connection between the amount sought to be deducted and the administration or management of shares or securities services provided to the taxpayer. ... In addition to the above test, the care and management fee levied by a trustee must meet the additional test imposed by the preamble to subsection 20(1) of the Act which provides that:..there may be deducted such of the following amounts as are wholly applicable to that source or such part of the following amounts as may reasonably be regarded as applicable thereto The wording of this portion of subsection 20(1) suggests that there must be a clear connection between the amount sought to be deducted and the source of the borrowing. ... That is, there must be a clear connection between the amount for which the deduction is sought and the administration or management of shares or securities services provided to the testamentary trust. ...

The Minister argued that the damages for mental distress and punitive damages in this case were clearly in connection with the loss of the office or employment of the taxpayer since they were awarded against the former employer as a result of the method and manner of the loss of employment or the firing, and that they bear a direct relation to the loss. ... In addition, the taxpayer's counsel had neither acknowledged nor denied that there was any direct connection, chronological or otherwise, between the "dismissal", and the "exemplary damages" or the amount for "mental distress". ... Horwitz in his argument had neither acknowledged nor denied that there was any direct connection, chronological or otherwise, between the "dismissal", and the "exemplary damages" or the amount for "mental distress". ...

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. ... In addition, in the case of Gregory Anderson (TCC), 98 DTC 1190, in finding that $42,345 in damages relating to real estate commission, legal fees and moving expenses qualified as a retiring allowance, the Court indicated (at page 1192) that: "In determining whether the damages received by the appellant were a retiring allowance, the word 'in respect of' in paragraph 248(1)(b) direct that a broad scope of inclusion be considered as to what constitutes a sufficient connection between the loss of employment and the amounts received. ...

Moreover, the fact that U.S. withholding and reporting may be required in connection with the distributions made by the Plan to Canadian recipients does not modify the applicable requirements under the Act. ... Besides, specific rules are provided in subsection 153(1) in connection with RCAs regarding amounts that have to be withheld and remitted by a payer to the Receiver General on account of the payee’s tax. ... If a reference to section 153 in subsection 207.7(4) was necessary to render these provisions applicable in connection to RCAs, none of these paragraphs would ever have any application. ...

31 August 2010 Internal T.I. 2009-0350531I7- Tax Treatment of Signing Bonus CRA Tags 54 12(1)(x) 9(1) 56.4 Principal Issues: What is the appropriate tax treatment to be afforded compensation received in respect a "signing bonus" paid by a XXXXXXXXXX company in connection with an agreement which grants an easement and settles related damage claims Position: The signing bonus constitutes an inducement pursuant to the express terms of the agreement. ... The activities undertaken by XXXXXXXXXX in connection with the XXXXXXXXXX construction create an interference and disturbance to XXXXXXXXXX vested rights and enjoyment of XXXXXXXXXX properties. ... Amounts payable in respect of the settlement of XXXXXXXXXX claims in connection with the granting of an easement are usually structured in a settlement agreement under various heads of compensation. ...

In this respect, clause 115(2)(e)(i)(B) excludes remuneration paid by a Canadian employer to a former resident of Canada where the payment is attributable to the duties of an office or employment performed outside Canada and the payment is made in connection with the selling of property, the negotiating of contracts or the rendering of services "in the ordinary course of a business carried on by the employer". ... In this connection, the phrase "rendering of services" is to be given its ordinary meaning and would include the performance of work or duties in respect of an office or employment. ... Obligations assumed in connection with and for the purpose only of betterment of property owned by a man do not necessarily constitute him a person who carries on business. ...

Subsection 212(5) of the Act provides that every non-resident person shall pay an income tax of 25% on every amount that a person resident in Canada pays or credits, or is deemed by Part I to pay or credit, to the non-resident person as, on account or in lieu of payment of, or in satisfaction of, 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 (other than solely in connection with and as part of a news program produced in Canada) that has been or is to be used or reproduced in Canada. ... Subsection 212(5) of the Act applies where a person resident in Canada pays to a non-resident person 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 (other than solely in connection with and as part of a news program produced in Canada) that has been or is to be used or reproduced in Canada. ...

In connection with this business, the BD Partnership pays royalties to Corporation X and Corporation X, in turn, pays royalties (in equal amounts) to Corporations A and C.  ...

Where an individual earns Remuneration, and is required to incur expenses in connection with that Remuneration, he or she is limited to the deductions under section 8 of the Income Tax Act. ...